UNIDO Payments AML Policy

Anti-Money Laundering and Anti-Terrorism Financing Policy of UNIDO Payments Payment Institution

UNIDO Payments Limited Liability Partnership is a payment institution in accordance with the record registration of the National Bank of the Republic of Kazakhstan, Payment Institutions Register No. 02-21-097 dated 08.07.2021, which provides services of processing payments initiated by customers in electronic form and transmitting required information to banks and/or organizations engaged in certain types of banking operations, to make a payment and/or to transfer or receive money under such payments.
For the purposes of countering legalization (laundering) of proceeds of crime and terrorist financing, UNIDO Payments LLP (the “Organization”) has developed and implemented an internal anti-money laundering and anti-terrorism financing control system (the “AML/ATF System”).
The Organization’s AML/ATF system is based on the principles of preventing the involvement of the Organization and its employees in any illegal activities related to the laundering of criminal proceeds, as well as eliminating the possibility of transactions related to the financing of terrorist activities:
AML/ATF system of the Organization has been developed in accordance with the requirements of the AML/ATF legislation of the Republic of Kazakhstan, legislative and regulatory acts of the National Bank of Kazakhstan and takes into account recommendations developed by international organizations — Financial Action Task Force (FATF), Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG) and others.
In its activities, the Organization follows the full transparency approach to the business relationship with our customers throughout the entire period of service, being guided by the Know Your Customer principle.
Pursuant to the provisions of the Law of the Republic of Kazakhstan dated August 28, 2009 No. 191-IV “On Combating Legalization (Laundering) of Criminal Proceeds and Financing of Terrorism” (the “Law”), the Organization has established the Anti-Money Laundering and Anti-Terrorism Financing Unit.
The Internal Control Regulations (the “AML/ATF Regulations”) are the comprehensive document regulating the Organization’s AML/ATF activities and describing the set of measures and procedures taken by the Organization for AML/ATF purposes. The implementation of the AML/ATF Regulations is ensured by a designated official of the Organization — the Compliance Officer accountable to the Organization's Chief Executive Officer.
In implementing the AML/ATF Regulations, the Organization shall ensure the following:

• application of money laundering and terrorism financing risk management procedures;
• documenting evidence (information) on AML/ATF issues;
• maintaining the confidentiality of information about measures taken by the Organization to ensure AML/ATF;
• timely submission of data (information) on AML/ATF issues to the authorized body (the National Bank of the Republic of Kazakhstan and/or the Financial Monitoring Agency of the Republic of Kazakhstan).

The AML/ATF system includes:

• identification of clients, clients’ representatives, beneficiaries, beneficial owners in accordance with the provisions of the Law and other regulatory legal acts of the Republic of Kazakhstan;
• examining and in-depth scrutiny of the customer by implementing the Know Your Customer principle, including standard of care and due diligence measures;
• identification of ultimate beneficial owners;
• implementing procedures to manage client risk and the risk of using services for criminal purposes, including the risk of using technological advances;
• analysis, monitoring, evaluation and control of all customer transactions to identify transactions suspected of being conducted for the purposes of money laundering and terrorism financing;
• mandatorily monitorable operations identification procedures;
• documenting and storing information;
• regular AML/ATF training for employees, taking into account changes in the current AML/ATF legislation.

The Organization works on an ongoing basis to update, modernize and implement new anti-legalization mechanisms and procedures aimed at improving the performance and efficiency of the AML/ATF System.