Anti-Money Laundering (AML) Policy

for OMNI NOVAS Groups

Last updated: October 28, 2023

This Anti-Money Laundering (AML) policy for OMNI NOVAS Groups, which partners using its marketplaces, credit platforms, P2P (Peer-to-Peer), P2B (Peer-to-Business), and B2B (Business-to-Business) transactions should adhere to.

 

1. Introduction OMNI NOVAS Groups (hereinafter referred to as “the Company”) is committed to maintaining the highest standards of ethical conduct and compliance with anti-money laundering (AML) laws and regulations. This AML policy outlines the Company’s approach to mitigating the risk of money laundering and financial crime in all activities conducted through its platforms and transactions involving its partners.

2. AML Compliance Officer The Company shall designate an AML Compliance Officer responsible for overseeing the implementation and enforcement of the AML program. The AML Compliance Officer shall maintain expertise in AML regulations, assess the risks specific to the Company’s operations, and ensure the effective execution of AML procedures.

3. Risk Assessment The Company shall conduct a comprehensive risk assessment to identify and understand the potential money laundering and terrorist financing risks associated with its business. This assessment will be regularly reviewed and updated to adapt to changing circumstances.

4. Customer Due Diligence (CDD)

• Know Your Customer (KYC): The Company will establish robust KYC procedures to verify the identity of partners, including individuals and entities. This includes obtaining and verifying identification and other relevant information.
• Enhanced Due Diligence (EDD): Enhanced due diligence will be applied to partners posing a higher risk, which may include politically exposed persons (PEPs) and high-risk jurisdictions.

5. Reporting and Recordkeeping

• The Company will maintain appropriate records of customer information, transactions, and AML measures taken.
• Partners will be required to report suspicious activities, regardless of the amount involved. Reports should be made to the designated AML Compliance Officer.

6. Transaction Monitoring

• The Company will establish and maintain transaction monitoring systems designed to detect unusual or suspicious transactions. Alerts generated by these systems will be promptly reviewed.

7. Training and Awareness The Company will provide regular AML training to its employees to ensure they understand the risks associated with money laundering and terrorist financing. Training will be tailored to each employee’s responsibilities within the Company.

8. Confidential Reporting The Company will establish a confidential reporting mechanism that allows employees, partners, or other stakeholders to report AML concerns without fear of retaliation.

9. Red Flags and Suspicious Activity

• The Company will maintain a list of red flags that could indicate potential money laundering or terrorist financing. Employees and partners should be aware of these indicators and report any suspicious activities.

10. Sanctions Compliance The Company will ensure compliance with international sanctions, including sanctions lists and asset freeze measures. Transactions with individuals or entities on such lists are prohibited.

11. Regulatory Reporting The Company will report any suspicious transactions or transactions meeting reporting thresholds to the appropriate regulatory authorities in compliance with local AML laws and regulations.

12. Periodic Reviews and Testing The Company shall regularly review, assess, and test the effectiveness of its AML program. This includes independent testing and reviews to ensure compliance.

13. Senior Management Approval The AML program, as outlined in this policy, has been approved in writing by senior management as reasonably designed to achieve and monitor the Company’s compliance with AML requirements.

14. Cooperation with Regulatory Authorities The Company will cooperate fully with regulatory authorities in any investigations related to money laundering or terrorist financing.

15. Non-Compliance Consequences Non-compliance with this AML policy may result in disciplinary actions or legal consequences.

16. Continuous Training and Education

• Ongoing training is essential to keep employees and partners updated on the latest AML trends and regulatory changes. Regular training sessions and resources should be made available.

17. AML Program Testing

• Regularly schedule and conduct independent testing and audits of your AML program to ensure its adequacy and effectiveness. This can include employing a third-party auditor with expertise in AML.

18. Screening and Watchlists

• Implement technology solutions that can screen partners and transactions against global sanctions lists, watchlists, and adverse media coverage to identify and mitigate risk.

19. AML Documentation and Records

• Maintain complete records of all AML compliance efforts. These records may be required to demonstrate your commitment to AML compliance in the event of regulatory inquiries.

20. Whistleblower Protection

• Ensure that there is a mechanism for whistleblowers to report AML concerns confidentially and that they are protected from retaliation.

21. Enhanced Risk Assessment

• Periodically review and update your risk assessment to account for emerging risks or changes in your business model. Ensure that higher-risk partners are subjected to more rigorous due diligence and monitoring.

22. Reporting and Cooperation

• Establish a clear procedure for reporting AML breaches to regulatory authorities. Cooperate fully in any investigations and examinations related to AML.

23. Third-Party Risk Management

• If you engage third-party service providers or vendors in your operations, ensure they also adhere to robust AML practices. Perform due diligence on these third parties and include compliance clauses in contracts.

24. Ethical Behavior and Compliance Culture

• Foster a culture of ethical behavior and compliance throughout the organization, from the top management to all employees and partners.

25. Adequate Resources

• Allocate sufficient resources, both human and financial, to effectively implement and maintain your AML program.

26. Cross-Border Transactions

• Pay close attention to cross-border transactions, as these often present higher AML risks. Ensure that AML procedures account for the international nature of your operations.

27. Public Reporting

• Publish an annual report or public statement affirming your commitment to AML compliance and detailing your efforts in this regard.

28. Penalties for Non-Compliance

• Clearly define penalties for employees, partners, and the organization itself in the event of AML non-compliance.

29. Updates and Amendments

• Commit to revising the AML policy to adapt to changing regulatory requirements and risks.

30. Employee Vetting

• Implement a robust vetting process for employees and partners. Screen potential hires and partners carefully to avoid inadvertently engaging with individuals or entities involved in money laundering activities.

31. EDD for High-Risk Partners

• Identify and apply Enhanced Due Diligence (EDD) procedures to high-risk partners, such as those operating in industries prone to money laundering or those from high-risk jurisdictions.

32. Geographic Risk Assessment

• Perform a geographic risk assessment to understand and mitigate risks associated with partners from regions with higher prevalence of money laundering and financial crimes.

33. Ongoing Monitoring

• Continue to monitor partner activity after onboarding, paying particular attention to deviations from established patterns or unusual transaction behavior.

34. Reporting Channels

• Provide partners with clear channels for reporting any suspicious activity they may encounter on your platforms. Encourage partners to share concerns to help protect the integrity of your marketplace.

35. Encryption and Data Security

• Ensure robust encryption and data security protocols to protect sensitive AML-related information. Unauthorized access to this information should be strictly prohibited.

36. Escalation Procedures

• Define clear escalation procedures for handling high-risk or suspicious activity, including the reporting of such activity to appropriate regulatory authorities when necessary.

37. Proactive AML Alerts

• Implement automated AML alerts to immediately flag any suspicious transactions or patterns of activity, ensuring timely response.

38. Documented Policies and Procedures

• Create comprehensive documentation that outlines AML policies and procedures, making them easily accessible to all employees and partners. Regularly update these documents to reflect changes in regulatory requirements.

39. AML Awareness

• Foster awareness about AML requirements among your partners. Consider offering educational resources to help them understand their AML responsibilities.

40. Records Retention

• Retain records of AML activities and reports, as these may be required for audits and regulatory inquiries.

41. Metrics and Reporting

• Establish Key Performance Indicators (KPIs) to measure the effectiveness of your AML program. Regularly report on AML program performance to management and regulatory bodies.

42. Emerging Technology

• Stay up-to-date with emerging technologies such as blockchain and cryptocurrency that may be vulnerable to money laundering activities. Adjust AML procedures as needed.

Conclusion OMNI NOVAS Groups is dedicated to maintaining the highest AML standards and ensuring that its partners’ transactions on its marketplaces, loan platforms, and various other platforms are conducted in a manner consistent with applicable AML laws and regulations. This policy is subject to periodic review and amendment to address changing AML risks and legal requirements. All partners and employees are expected to adhere to these AML principles to uphold the Company’s commitment to financial integrity.

This AML policy is provided as a general framework and should be tailored to OMNI NOVAS Groups’ specific needs and the legal requirements of the jurisdictions in which it operates.