FINANCIAL CRIME INVESTIGATION SERVICES OF THE MINISTRY OF THE INTERIOR OF THE REPUBLIC OF LITHUANIA
ON THE ADOPTION OF INSTRUCTIONS TO DEPOSITORY VIRTUAL CURRENCY OPERATORS AND VIRTUAL CURRENCY EXCHANGE OPERATORS ON THE PREVENTION OF MONEY-LAUNDERING AND (OR) THE FINANCING OF TERRORISM
Approved by Financial crime investigation services under the Republic of Lithuania director of the Ministry of the Interior Order No V-5 of 10 January 2020
INSTRUCTIONS TO DEPOSITORY VIRTUAL CURRENCY OPERATORS AND VIRTUAL CURRENCY EXCHANGE OPERATORS ON THE PREVENTION OF MONEY-LAUNDERING AND (OR) FINANCING OF TERRORISM
Chapter I
GENERAL PROVISIONS
1. Instructions to Virtual Currency Purse Depository Operators and Virtual Currency Exchange Operators on Preventing Money Laundering and/or Terrorist Financing (hereinafter – «Instructions»)Applicable to monetary operators of generic virtual currencies and operators of virtual currency exchange offices, establishing requirements for the implementation of legislative requirements for the prevention of money-laundering and/or the financing of terrorism and operating procedures of the operator virtual currency purse and virtual currency exchange operator.
2. The concepts used in this document correspond to those defined in the Republic of Lithuania Law on Prevention of Money Laundering and Financing of Terrorism (hereinafter – the Law).
3. The Monetary Operator of Virtual Currency Deposits and the Operator of the Virtual Currency Exchange shall apply the Act in implementing measures to prevent money-laundering and/or the financing of terrorism, Order No V-131 of 12 September 2017 of the Director of the Financial Crimes Investigation Service of the Ministry of the Interior of the Republic of Lithuania (hereinafter – Financial Crimes Investigation Service) «About the description of the approval procedure and the submission of a copy of the identity document». Approval», Order of the Director of the Financial Crimes Investigation Service No V-314 of 30 November 2016 «On Approval of Technical Requirements for Customer Identification Process with Remote Identification by Electronic Means Providing Live Video Broadcasting»The Order of the Director of the Financial Crimes Investigation Service No V-273 on the Proper Application of International Financial Sanctions is the Regulatory Service of the Ministry of the Interior of the Republic of Lithuania and these Instructions.
Chapter II Provisions in chapter I
MEASURES TO COMBAT MONEY-LAUNDERING AND/OR FINANCING OF TERRORISM
4. The money operator of the virtual currency deposit and the operator of the virtual currency exchange point implement the following measures to prevent the laundering of information/or the financing of terrorism:
4.1. Identification of client and beneficiary:
4.1.1. Determination of whether the client acts on its behalf or is controlled;
4.1.2. If the client acts through a representative, identifying the client’s representative;
4.1.3. Identification of the customer as an individual;
4.1.4. Identification of the client as a legal person;
4.1.5. Identification of the client’s beneficiary as a legal person;
4.1.6. Collection of information on the client management legal entity;
4.1.7. Collection of information on the ownership and control structure and nature of the client’s business as a legal entity;
4.1.8. Gathering information on the purpose and intended nature of the customer’s business relationship, whether natural or legal;
4.1.9. Verification of the identity of the client and beneficiary on the basis of documents, data or information obtained from a reliable and independent source; 4.1.10.1 Continuous monitoring of the client’s business relationship;
4.1.11.1. Continuous review and updating of documents, data or information provided by the client and beneficiary in the identification;
4.2. Where it is not possible to meet the requirements for identification of the applicant and of the debtor, failure to perform the transactions, failure to establish the business relationship, Termination;
4.3. Application of customer and beneficiary identification tools not only to innovations but also to existing clients (Clients who became clients of the virtual currency purse operator and the virtual currency exchange operator before 10 January 2020, these measures are applied on the basis of their level of risk, starting with clients with higher risk, without delay but not later than 1 July 2020);
4.4. Suspension of the suspicious monetary transaction or transaction;
4.5. Reporting of suspicious monetary transactions or transactions;
4.6. Notification of virtual currency or virtual currency transactions if the value of such monetary transaction or transaction is equal to or greater than 15,000 EUR or the foreign or virtual currency equivalent, whether the transaction is in one or more related monetary transactions;
4.7. Examining the structure of complex or abnormally large transactions and unusual transactions;
4.8. Storage of information for a certain period of time;
4.9. Designation of officials responsible for implementing measures to combat money-laundering and/or the financing of terrorism;
4.10. Training of staff;
4.11. Introduce internal systems to respond promptly to requests from the Financial Crimes Investigation Service through secure channels and to ensure full confidentiality of requests;
4.12. Confidentiality of information provided to the Financial Crimes Investigation Service;
4.13. Establishment of internal policies and procedures for internal control; 4.14.Provide information on the beneficiaries of the depository currency of the money operator and the operator of the virtual currency exchange point to the Administrator of the Information System of Legal Participants (JADIS).
Chapter III Provisions in the first chapter
IMPLEMENTATION OF MEASURES AGAINST MONEY-LAUNDERING AND/OR THE FINANCING OF TERRORISM
FIRST SECTION
IDENTIFICATION OF CLIENT AND BENEFICIARY
5. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange should take steps to identify and verify the identity of the client and the recipient:
5.1. Before entering into a business relationship;
5.2. Before performing a single (one-time) virtual currency exchange operation or a one-time (2007) transaction. From time to time, transactions in virtual currency with funds equal to or exceeding €1,000 or the corresponding amount in foreign or virtual currency, or by a one-time transaction (EUR 1,000). From time to time, deposit in the deposit book or one-time ($100 million) virtual currency. From time to time, the withdrawal of a virtual currency for an amount equal to or greater than €1,000 or a corresponding amount in foreign or virtual currency, regardless of whether the transaction is in one or more interrelated transactions (the value of the virtual currency is determined at the time of the monetary transaction or transaction) if the client and beneficiary are no longer identified;
5.3. Where there is doubt as to the correctness or authenticity of the previous identification of the client and the beneficiary;
5.4. In any other case where money-laundering and/or the financing of terrorism is suspected to occur, have occurred or will occur.
6. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange carry out the identification of the client and the beneficiary in accordance with the provisions of articles 9 to 15 of the Law, using a risk-oriented approach using:
6.1. Normal means and procedures for customer identification;
6.2. Additional tools and procedures for customer identification to conduct enhanced customer identification;
6.3. Simplified customer identification tools and procedures to facilitate customer identification.
7. In such cases where the monetary operator of the virtual currency deposit and the virtual currency exchange operator are unable to comply with the requirements set out in paragraphs 4.1.1 to 4.1.10 of these instructions, the monetary operator of the deposit of virtual currencies and the operator of the virtual currency exchange shall comply with the prohibition on conducting transactions through bank accounts set out in article 9, paragraph 18, of the Law, to establish or continue business relationships, conduct operations and assessments of the threat of money-laundering and/or the financing of terrorism. Having identified the threat of money laundering and/or terrorist financing, the money operator of the deposit of virtual currencies and the operator of the virtual currency exchange office report the suspicious money transaction or transaction to the Financial Crime Investigation Service.
SECTION II
SIMPLIFIED CUSTOMER IDENTIFICATION
8. If the Virtual Currency Deposit Operator and the Virtual Currency Exchange Point Operator seek to apply a simplified identification of the customer in the cases provided for in article 15, paragraph 1, of the Law, they must conduct a risk assessment and have evidence of: that a low risk of money laundering and/or terrorist financing has been identified. Risk assessment data are stored in the same order as other data received at the time of customer identification.
9. The money operator of the virtual currency deposit and the operator of the virtual currency exchange point are obliged to regularly monitor the customer’s business relations, including by assessing whether the risk of money laundering and/or terrorist financing by the client remains low.
THIRD SECTION
IMPROVED CUSTOMER IDENTIFICATION
Politically vulnerable (vulnerable) persons
10. When the client – natural person or client – beneficiary of a legal entity is politically vulnerable (exposed) person, the money operator of the deposit
the virtual currency and the operator of the virtual currency exchange point are obliged to apply the measures specified in article 14, paragraph 3, of the Law.
11. The monetary operator of the Virtual Currency Depository and the Virtual Currency Exchange Point Operator determine in internal control policies and procedures what measures they apply during when a politically exposed person ceases to perform important public duties until it is established that the person no longer poses a risk to politically vulnerable persons (for at least 12 months). Risk assessment data are stored in the same order as other data received at the time of customer identification.
Third high-risk countries
12. If the client, an individual or client beneficiary of a legal entity, resides in a third high-risk country or where the client is a legal entity established in a third high-risk country, The monetary operator of the depositary virtual currency and the operator of the virtual currency exchange point shall apply the measures set out in article 14, paragraphs 1 and 5, of the Act.
13. European Commission Regulation (EU) No 2016/1675 of 14/07/2016 establishes the list of third high-risk countries with the European Commission, published in the section «International Law» of Chapters www.fntt.lt on Prevention of Money Laundering on the web.site and database EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R1675 of European Union legislation.
14. The list of high-risk third-party Financial Action Task Force on Money Laundering and Financing of Terrorism (FATF) is published in the section «FATF Statements» of the www.fntt.lt website and on the FATF website https://www.fatf-gafi.org/countries/ and https://ww.fatf-gafi.org/coun tries/#high-risk.
15. In order to ascertain whether transactions or dealings are conducted with individuals residing in high-risk countries or with legal entities, The Virtual Currency Depository Cash Operator and the Virtual Exchange Point Operator shall check both lists of high-risk third countries referred to in paragraphs 13 and 14 of these Instructions.
16. In the cases provided for in article 14, paragraph 5, of the Act, the monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point shall be defined in internal policies and procedures of internal control, What or some additional measures of customer and beneficiary identification are taken at their discretion to mitigate risks, such as:
16.1. Obtain additional information on the client and beneficiary;
16.2. Obtain additional information on the expected nature of the business relationship;
16.3. Obtain information on the source of funds and assets of the client and the beneficiary;
16.4. Obtain information on the reasons for transactions planned or carried out;
16.5. Obtain the approval of a senior manager to establish a business relationship with these customers or consent to continue business with these customers;
16.6. Strengthen continuous monitoring of business relationships with these customers by increasing the number and duration of controls and the types of transactions that will require further investigation;
16.7. Guarantee that the customer’s first payment is made from the customer’s account in a credit institution where the credit institution is registered in a Member State of the European Union or in a third country which has requirements equivalent to those of established by this Law and the competent authorities shall monitor compliance with these requirements.
17. If the money operator of the Virtual Currency Deposit and the Virtual Exchange Point Operator apply the derogation specified in Article 14(1)(3) of the Act, to subsidiaries or subsidiaries of financial institutions or other liable persons established in the European Union, The monetary operator of the depository virtual currencies and the operator of the virtual exchange point should conduct a risk assessment and have evidence that the risks identified are not significant. Risk assessment data are stored in the same order as other data received at the time of customer identification.
Increased risk of money-laundering and/or terrorist financing
18. When the monetary operator of the virtual currency deposit and the operator of the virtual exchange point determine, in accordance with risk assessment and management procedures, a higher risk of money-laundering and/or terrorist financing, The monetary operator of the deposit virtual currencies and the operator of the virtual currency exchange point shall apply the measures set out in article 14, paragraph 5, of the Law.
19. The monetary operator of the depositary virtual currency and the operator of the virtual currency exchange point determine in internal policy and internal control procedures, Which of these are being implemented, at their discretion, one or more additional measures to identify the client and beneficiary to mitigate emerging risks, such as:
19.1. Obtain additional information on the client and beneficiary;
19.2. Obtain additional information on the expected nature of the business relationship;
19.3. Obtain information on the source of funds and assets of the client and the beneficiary;
19.4. Obtain information on the reasons for planned or implemented transactions;
19.5. Obtain the approval of a senior manager to establish a business relationship with these customers or consent to continue business relations with these customers;
19.6. Strengthen the continuous monitoring of business relationships with these customers by increasing the number and duration of controls and selecting types of transactions that will require further investigation;
19.7. Guarantee that the customer’s first payment is made from the customer’s account in a credit institution where the credit institution is registered in a Member State of the European Union or in a third country which has requirements, equivalent to those established in this Law and the competent authorities shall monitor compliance with these requirements.
20. Risk assessment data are stored in the same order as other data from the moment of identification of the client.
CHAPTER FOUR
MONITORING OF BUSINESS RELATIONS
21. When a business relationship with a client begins, the monetary operator of the virtual currency deposit and the operator of the virtual exchange office must monitor the business relationship to ensure that the transactions made correspond to the information, available to virtual currency depository, money operator and operator of virtual exchange about the client, its business, risk profile and source of funds.
22. Virtual Currency Cash Deposit Operator and Virtual Currency Exchange Point Operator classify clients with whom a business relationship has been established as risk according to the criteria and procedures for assigning clients to risk groups, as set out in their internal policies and procedures for internal control.
CHAPTER FIVE
SUPPRESSION OF SUSPICIOUS TRANSACTIONS OR OPERATIONS AND REPORTING TO THE FINANCIAL CRIMES INVESTIGATION SERVICE
23. The money operator of the deposit of virtual currencies and the operator of the virtual currency exchange item, in accordance with Article 16 of the Law, suspend the suspicious monetary transaction or transaction if this is objectively impossible.
24. Suspicious monetary transactions or transactions must be detected:
24.1. Taking into account the criteria for detecting suspicious monetary transactions or transactions approved by order of the Director of the Financial Crimes Investigation Service No V-240 of 5 December 2014 on the adoption of a list of criteria for money-laundering and the detection of suspicious monetary transactions or transactions;
24.2. Drawing attention to customer activities that by their very nature may be related to money laundering and/or the financing of terrorism;
24.3. Identification of the client and the beneficiary;
24.4. Continuous monitoring of the customer’s business relationship, including investigation of transactions made in the course of the relationship.
25. Monetary Operator of Deposited Virtual Currencies and Operator of Virtual Currency Exchange are obliged under Article 16 of the Law to notify the Financial Crimes Investigation Service of information on suspicious money transactions or transactions not later than in within 3 working hours.
26. Suspicious money transactions or transactions are reported regardless of the size of the money transaction or transaction.
27. The Virtual Currency Exchange Operator notifies the Financial Crimes Investigation Service, in accordance with article 20 of the Act, of the identity of the client and the information on the virtual currency exchange operation carried out (purchase or sale of virtual currency in the currency of the decree) or transaction in virtual currency (payments in virtual currency for assets) if the value of such monetary transaction or transaction is equal to or greater than EUR 15,000 or equivalent. Foreign currency or virtual currency, whether the transaction is in the form of one or more interrelated monetary transactions. The value of a virtual currency is determined at the time of a money transaction or transaction.
28. Where a money transaction or a transaction of a customer satisfies both the characteristics of paragraph 24 and paragraph 27 of this Instruction, the money operator of the depository virtual currency and the operator of the virtual currency exchange office must submit to the Financial Crimes Investigation Service both reports, or a report of a suspicious money transaction or transaction, or a notification of a virtual currency exchange transaction or a virtual currency transaction, provided that the value of such monetary transaction or transaction is equal to or equal to the value of the transaction; exceeds EUR 15,000 or the equivalent in foreign or virtual currency, whether the transaction is one or more linked monetary transactions.
29. Notifications to the Financial Crimes Investigation Service are made in accordance with the Order of the Minister of Internal Affairs of the Republic of Lithuania No 1V-701 of 16 October 2017 On suspending suspicious monetary transactions or transactions and submitting information on suspicious monetary transactions or transactions to the Financial Crimes Investigation Service of the Ministry of Internal Affairs of the Republic of Lithuania and information on cash transactions or deals, whose amount is equal to or greater than 15,000 euros or the corresponding amount in foreign currency, approval of the procedure of the Financial Crimes Investigation Service under the Ministry of the Interior of the Republic of Lithuania», Order No V-129 of 21 May 2015 of the Director of the Financial Crimes Investigation Service On the forms of provision of information, provided in accordance with the requirements of the Law of the Republic of Lithuania on Prevention of Money Laundering and Financing of Terrorism, the scheme of submission and acceptance of recommendations for completion of the submission forms”.
CHAPTER SIX
STORAGE OF INFORMATION AND DOCUMENTS
30. The money operator of the deposit of virtual currencies and the operator of the virtual currency exchange should keep the following logs:
30.1. Register of reports and suspicious monetary transactions and transactions specified in article 16, paragraph 1, of the Act;
30.2. Journal of monetary transactions performed by the client referred to in article 9, paragraph 1, paragraphs 2 to 6, of the Act;
30.3. Virtual currency or virtual currency transactions, provided that the value of such monetary transaction or transaction is equal to or greater than 15,000 euros or the foreign or virtual currency equivalent, whether the transaction is in the context of one or more related monetary transactions;
30.4. Register of clients with whom transactions or business dealings have been terminated in the circumstances specified in article 18 of the Act or in other circumstances related to violations of the procedure for preventing money laundering and (or) financing of terrorism.
31. Data shall be entered in the registers in chronological order without delay and not later than within 3 working days from the time of the money transaction or transaction.
32. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange give priority to the electronic storage of the log’s registration data.
33. The registers are kept in accordance with Order No V-129 of 4 September 2017 of the Director of the Financial Crimes Investigation Service of the Ministry of the Interior of the Republic of Lithuania «On approval of rules of processing of money transactions, transactions and registers of clients».
SECTION SEVEN
EMPLOYEES
34. The money operator of the virtual currency depository and the operator of the virtual currency exchange should appoint management staff to organize the implementation of measures to prevent money-laundering and the financing of terrorism and to liaise with the Investigation Service of financial crimes. If the monetary operator of the virtual currency deposit and the operator of the virtual exchange point are managed by the board, The monetary operator of the depositary virtual currencies and the operator of the virtual exchange point shall appoint a member of the Council to organize the implementation of the measures against money-laundering and / or the financing of terrorism set forth in this Law, and management personnel to cooperate with the Financial Crimes Investigation Service. These officers should be notified in writing q to the Financial Crimes Investigation Service by the Virtual Currency Money Operator and the Virtual Exchange Point Operator. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point should ensure that said employees have access to all information necessary for the performance of their functions, including access to information, related to customer and beneficiary identification, customer business relations monitoring, money transactions and transactions.
35. The money operator of the depository virtual currency and the operator of the virtual exchange point should provide specialized training to their employees on measures to combat money-laundering and / or the financing of terrorism, especially for those who work directly with clients and their transactions.
CHAPTER EIGHT
INTERNAL CONTROL PROCEDURES
36. The monetary operator of the Virtual Currency Deposit and the Virtual Currency Exchange Point Operator should specify in detail in the internal policy and internal control procedures, How the money operator of the depositary virtual currencies and the operator of the virtual currency exchange point are to implement the measures referred to in article 29, paragraph 1, of the Law.
37. To effectively manage the risks of money-laundering and terrorist financing, the virtual currency purse operator and the virtual currency exchange operator must assess the risk of money-laundering and terrorist financing of all their activities at least once per year, with the latest information.
38. All risk assessments of all money-laundering and terrorist financing activities carried out by the Virtual Currency Purse Operator and the Virtual Currency Exchange Point Operator and subsequent changes related to this risk assessment, must be documented in writing.
39. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange point should review and, if necessary, update internal control procedures:
39.1. Publication by the European Commission of a pan-European assessment of the risks of money-laundering and the financing of terrorism (available on the European Commission website ec.europa.eu);
39.2. Publication of the results of the National Assessment of the Risks of Money Laundering and Terrorist Financing (published in the section «Prevention of Money Laundering wwww.fntt.lt in the subsection «National Assessment of the Risks of Money Laundering and Terrorist Financing»);
39.3. Strengthen the applicable internal control procedures as directed by the Financial Crimes Investigation Service;
39.4. In the event of significant events or changes in the management and operation of the virtual currency depository of the money operator and the virtual currency exchange operator;
39.5. Periodic monitoring of the implementation and adequacy of internal control procedures.
Chapter IV Provisions in chapter I
IMPLEMENTATION OF INTERNATIONAL FINANCIAL SANCTIONS
40. The monetary operator of the virtual currency deposit and the operator of the virtual currency exchange office must, in each specific case, before entering into a relationship with the client or entering into a transaction, ensure that the client, the beneficiary and/or the client’s representative are not included in the lists of persons, subject to international financial sanctions.
41. The consolidated list of sanctions of the European Union is published on the European Commission website https://eeas.europa.eu/topics/sanctions-policy/8442/consolidated-list-sanctions_en.
42. The United Nations consolidated list of sanctions is published on the United Nations website https://www.un.org/sc/suborgen/sanctions/un-sc consolidated-list.
43. In order to verify that transactions are not carried out, business relations are not maintained or established with persons subject to international financial sanctions, and it is necessary to check the lists of persons, which are subject to international financial sanctions, both in the European Union and in the United Nations, in order to verify that there are no transactions.
44. The money operator of the virtual currency deposits and the operator of the virtual currency exchange office shall comply with the Law of the Republic of Lithuania on the Implementation of Economic and Other International Sanctions, Regulations of the Government of the Republic of Lithuania on the Implementation of International Sanctions, Regulations of the European Union on International Sanctions and Exemptions from their Application and Order No V273 Directors of the Financial Crimes Investigation Service, dated 20 October 2016, on the appropriate requirement for the approval of oversight instructions for the implementation of international financial sanctions in the area of the regulation of the Financial Crimes Investigation Service Ministry of the Interior of the Republic of Lithuania.
CHAPTER V
FINAL PROVISIONS
45. The provisions of the amended Laws of the Republic of Lithuania, Government Decrees and other legal acts must be implemented immediately, without waiting for these Instructions to be amended or supplemented.
46. The monetary operator of the deposit of virtual currencies and the operator of the virtual currency exchange, having violated the requirements of these instructions, shall be liable in the manner prescribed by law.
47. Virtual Currency Money Operator and Virtual Exchange Point Operator for Prevention of Laundering and/or Financing of Terrorism, are requested to check the quality of implementation of measures through a self-monitoring questionnaire (Annexes)which is a help in meeting the requirements.
Measures to combat money-laundering and/or the financing of terrorism
1. Before entering into a business relationship; (k), the customer performs virtual currency exchange or virtual currency transactions with funds equal to or exceeding 1,000 Euro or foreign or virtual currency equivalent, or before making a deposit or withdrawal of a virtual currency with an amount equal to or greater than €1,000 or a corresponding amount in foreign or virtual currency, whether the transaction is in the context of one or more interrelated transactions (The value of the virtual currency is determined at the time of the monetary transaction or transaction) if the identity of the client and beneficiary is not established; If there is doubt as to the correctness or authenticity of the previously obtained identity of the client and beneficiary; in any other case, if there is a suspicion that there is, money laundering and/or the financing of terrorism has been or will be carried out, The client and the beneficiary shall be identified:
1.1. Determine whether the client is acting on his behalf or is under control
1.2. A copy of the identity document or residence permit in the Republic of Lithuania is made or the document is scanned
1.3. Verification of circumstances for the extended identification of clients
1.4. The identity of the client – natural person is established; a copy of the identity or residence permit in the Republic of Lithuania is made or the document is scanned
1.5. Identification of client – legal entity
1.6. Identify the client’s beneficiary as a legal person
1.7. Collects information on the head of the client’s legal entity
1.8. Collection of information on the ownership and control structure and client nature of the legal entity
1.9. Collects information on the purpose and intended nature of the client’s business relationship – natural or legal person
1.10. The identity of the client and beneficiary is verified on the basis of documents, data or information obtained from a reliable and independent source
1.11. Constant monitoring of the customer’s business relations
1.12. Continuous review and updating of documents, data or information provided by the client and beneficiary at the time of identification
2. Transactions are not carried out, business relationships are not established, they are terminated if it is impossible to carry out the identification of the applicant and the beneficiary
3. The customer and beneficiary identification tools apply not only to novelties, but also to existing customers
4. Suspicious monetary transaction or transaction made by the client is suspended if objectively impossible.
5. Suspicious money transactions or transactions shall be reported to the Financial Crimes Investigation Service within 3 working hours at the latest.
6. The virtual exchange operator shall, within 7 working days at the latest, report to the Financial Crimes Investigation Service on the exchange of virtual currency or transactions in virtual currency, If the value of such monetary transaction or transaction is equal to or greater than EUR 15,000 or the foreign or virtual currency equivalent, regardless of whether the transaction is in the form of one or more interconnected money.
7. Monitor and work with complex or unusually large transactions and unusual transaction structures
8. Records and information shall be kept no later than 3 working days.
9. Information is kept for 8 years (correspondence of business relationship with client – 5 years)
10. An officer has been appointed to implement measures to combat money-laundering and/or the financing of terrorism, as reported in writing to the Financial Crimes Investigation Service.
11. In-service training of staff
12. Internal systems are in place to respond quickly to requests from the Financial Crimes Investigation Service through secure channels and full confidentiality of requests.
13. Information provided to the Financial Crimes Investigation Service is protected
14. Periodic risk assessment and response to money-laundering and/or terrorist financing by client, product, geographical region to mitigate these risks
15. Established internal policies and procedures for internal control
16. Information on the beneficiaries of the deposit of the virtual currency operator and the operator of the virtual currency exchange point is available to the Manager of the Information System of Participants of Legal Entities (JADIS)
17. Measures to implement financial sanctions
