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).