Pagotec Consultancy Ltd formal Anti Money Laundering and Compliance program require approval of senior management. Our legal and regulatory compliance program includes a designated Compliance Officer that is responsible for coordinating and overseeing the AML and Compliance program on a day-to-day basis. We have developed written policies documenting the processes that we have in place to prevent, detect and report suspicious transactions. Pagotec Consultancy LTD is committed to maintaining effective prevention and detection measures to assist the law enforcement authorities in combating financial crime.

In addition to inspections by the government supervisors/regulators, Pagotec Consultancy Ltd has an internal audit function and independent third-party reviewers that assess AML policies and practices on a regular basis. We have policies covering relationships with politically exposed persons consistent with industry best practices.

Pagotec Consultancy Ltd has implemented systems for the identification of its customers, including customer information in the case of recorded transactions, account opening, etc. We perform a risk-focused assessment of our customer base and their transactions. We determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that we have reason to believe pose a heightened risk of illicit activities. Know Your Customer (KYC) Information is collected at account opening and reviewed on periodic intervals. Pagotec Consultancy Ltd takes steps to understand the normal and expected transactions of its customers based on its risk assessment of them. We have appropriate record retention procedures that exceed the requirements of the applicable law, as well as clear policies regarding Anti Bribery and Corruption practices.

Pagotec Consultancy Ltd has policies and practices for the identification and reporting of transactions that are required to be reported to the authorities. Our systems are programmed to identify transactions structured to avoid regulatory reporting requirements. We screen transactions of customers against lists issued by government/international bodies (e.g., OFAC, HM Treasury, UN Security Council and our own internal sanctions list) prior to completing any such transactions.

Pagotec Consultancy Ltd provides AML training to all employees that include identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving the Company’s products and services and internal policies to prevent money laundering. Pagotec Consultancy Ltd retains records of its training sessions including attendance records and relevant training materials used. Pagotec Consultancy Ltd has policies to communicate new AML related laws or changes to all employees.