AML measures

In accordance with the legal regulations of the Czech Republic, Direct Fidoo Payments s.r.o., as a payment institution supervised by the Czech National Bank and as an obliged person under Act No. 253/2008 Coll., on certain measures against the legalization of proceeds of crime and terrorist financing, must:

• define and implement its own anti-money laundering and counter-terrorist financing policy, including the application of the Know-your-customer rules;
• identify their clients, including the obligation to update their identification data;
• to carry out checks on clients according to their risk profile, to carry out regular periodic checks on clients and ad hoc checks on the basis of control alerts that affect the riskiness of clients;
• report suspicious transactions to the relevant authorities;
• request information from clients in accordance with legal obligations and retain it for 10 years after the termination of the business relationship;
• to screen clients and their transactions for money laundering and terrorist financing;
• train all Fidoo team members in AML, KYC, CFT, international sanctions, etc.

Internal regulations of Direct Fidoo Payments s.r.o.

Direct Fidoo Payments s.r.o. declares that it has zero tolerance for any activities related to money laundering and terrorist financing.

The management of the AML/CFT policy is not the responsibility of the Compliance team alone, but is the responsibility of all members of the Fidoo team who are subject to the relevant rules and procedures.
All Fidoo team members are regularly trained on topics related to the prevention of money laundering and terrorist financing.

The company has established a comprehensive system of AML/CFT rules and internal regulations.

Internal regulations:

• They define basic principles and working practices in the area of prevention of money laundering and terrorist financing and Know Your Customer rules.
• It sets out the due diligence rules applicable to clients, including information on the documentation required, according to the risk category of the client.
  The company distinguishes 4 categories (low risk, medium risk, high risk, unacceptable client).
  The legal entity must always provide the ownership and management structure of the owner of the company / beneficial owner with a shareholding of 25% or more, information on business activity, type of business, revenues and other information related to the purpose of using Fidoo services or the source of funds.
  All persons acting on behalf of the client must be identified in accordance with the legal requirements of the Czech Republic.
• It sets out rules for clients – politically exposed persons, persons close to PEPs and state-owned companies.
• They define the procedures for determining the risk profile of a client.
• It establishes a process for screening against PEP lists, sanction lists, negative information, upon entering into a business relationship and also during periodic reviews (weekly, monthly, quarterly, annual).
• It establishes procedures for identifying and detecting suspicious transactions.
• They define rules and procedures for monitoring transactions, generating alerts and reporting suspicious trades.
• Sets out the process for terminating the business relationship.
• It sets out the responsibility of the Compliance team to implement appropriate policies and procedures within the company.
• Mandates mandatory AML training at least once every 12 months.

Legislation:

• Act 253/2008 Coll., on certain measures against the legalization of the proceeds of crime and the financing of terrorism;
• Decree No. 235/2021 Coll., on certain requirements for a system of internal policies, procedures and control measures against the legalization of proceeds of crime and terrorist financing;
• Act No. 37/2021 Coll., on the registration of beneficial owners;
• Act No. 69/2006 Coll., on the implementation of international sanctions.