1. General provisions

1.1. This Policy in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds (hereinafter referred to as the Policy) has been developed based on the requirements of the Law of the Kyrgyz Republic dated August 6, 2018 No. 87 "On Countering the Financing of Terrorist Activities and the Legalization (Laundering) of Criminal Proceeds" (hereinafter referred to as the Policy). – The Law on Counteraction), as well as on the basis of the Regulation on the General Requirements for the Internal Control Program and the Regulation on the Procedure for Conducting Due Diligence of the Client, approved by Resolution No. 606 of the Government of the Kyrgyz Republic dated December 25, 2018.

The Policy defines the main goals, objectives, requirements of internal control for the purpose of combating the financing of terrorist activities and legalization (laundering) of proceeds of crime and programs for its implementation in “TakeRoyal-Finance” LLC (hereinafter - the Company).

1.2. The effect of this Policy shall apply to all subdivisions of the Company, as well as branches and representative offices, subsidiaries that carry out transactions with cash or other property.

1.3. The function of control over compliance with this Policy shall be vested in the General Director of the Company.

1.4. The Policy defines the procedure for:

- organization of internal control, including powers and responsibility of officials in the field of countering the financing of terrorist activities and legalization (laundering) of criminal proceeds;

- identification of clients and monitoring of clients' activities;

- detection of operations (transactions) with cash or other property subject to mandatory control and (or) suspicious operations (transactions) in clients' activities;

- providing the financial intelligence unit with information on the identified operations (transactions) with cash or other property subject to mandatory control and (or) suspicious operations (transactions);

- assessment of risks related to financing of terrorist activities and legalization (laundering) of proceeds of crime;

- documenting, storing and ensuring confidentiality of information obtained in accordance with the Law on Counteraction and other legal and regulatory acts of the Kyrgyz Republic in the sphere of countering the financing of terrorist activities and legalization (laundering) of proceeds of crime;

- education (training) of the Company's employees in the field of countering the financing of terrorist activities and legalization (laundering) of proceeds of crime.

1.5. The following basic concepts and terms shall be applied in this Policy:

1) beneficial owner - an individual (individuals) who ultimately (through the chain of ownership and control) directly or indirectly (through third parties) owns the ownership right or controls the client or an individual on whose behalf or in whose interests the transaction (deal) is made;

2) verification — the procedure for verifying the identification data of the client and (or) the beneficial owner;

3) high risk countries - states and territories (entities) that do not apply or insufficiently apply international standards on combating money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction, as well as offshore zones;

4) business relations - relations between the client and the Company that have arisen on the basis of an agreement (oral or written) on the provision of services for the implementation of an operation (transaction);

5) freezing of operation (transaction) and (or) funds - prohibition to conduct operation (transaction) with funds or transfer, transformation, alienation and movement of any funds;

6) identification - a procedure for establishing identification data on the client and (or) beneficial owner;

7) client - a natural or legal person (organization), foreign trust or legal entity accepted for servicing or serviced by the Company;

8) legalization (laundering) of proceeds of crime - making the possession, use or disposal of criminal proceeds lawful by means of any actions (operations or transactions) on transformation (conversion) or transfer of property, if it is known that the property represents the proceeds of crime, in order to conceal or disguise the criminal source of origin of the property or to assist a person involved in the commission of a crime in order to evade responsibility for the acts; or concealment or disguise of the true nature of the source, location, manner of disposition and movement of the property, as well as the rights to or ownership of the property, if it is known that the property represents the proceeds of crime; or concealment or continued retention of the property by a person who did not participate in the commission of the crime, if the person knows that the property is derived from the commission of the crime; or the acquisition, possession or use of property if, at the time of receipt, the person knew that the property was the proceeds of crime;

9) operations (transactions) - any operations (transactions) with funds made to establish, change or terminate civil rights and obligations with funds;

10) financial Intelligence unit - an authorized state body of the Kyrgyz Republic in the field of combating the financing of terrorist activities and legalization (laundering) of proceeds of crime, established by the President of the Kyrgyz Republic;

11) suspension of an operations (transactions) - a temporary prohibition to conduct an operation (transaction) with funds;

12) public officials - one of the following natural persons:

a) foreign public official - a person who performs or has performed significant state or political functions (public functions) in a foreign state (heads of state or government, top officials in the government and other state bodies, courts, armed forces, state enterprises, as well as prominent political figures, including prominent figures of political parties);

b) national public official - a person who holds or has held a political and special public office or a political municipal office in the Kyrgyz Republic provided for by the Register of public and municipal offices of the Kyrgyz Republic approved by the President of the Kyrgyz Republic, as well as senior management of public corporations, prominent political figures, including prominent figures of political parties;

c) public official of an international organization - the highest official of an international organization who is or has been entrusted with an important function by an international organization (directors, deputy directors and board members of an international organization or persons holding equivalent positions in an international organization);

13) risk-oriented approach - application of enhanced measures in case of high risk or simplified measures in case of low risk in accordance with established risk management procedures (identification, assessment, monitoring, control, risk mitigation);

14) Sanctions lists lists of individuals, legal entities, groups and organizations in respect of which there is information about their involvement in terrorist or extremist activities and proliferation of weapons of mass destruction, in particular:

- Consolidated Sanctions List of the Kyrgyz Republic,

- UN Security Council Consolidated Sanctions List.

15) funds - one of the following assets:

- money (cash and non-cash) in any currency and any financial assets (including virtual assets);

- property of any kind (tangible or intangible, movable or immovable) regardless of the method of acquisition;

- legal documents or instruments in any form, including electronic or digital, granting the right or interest to the above property or assets;

16) accounts - bank accounts, as defined in the banking legislation of the Kyrgyz Republic, or similar business relations between the Company and the client;

17) targeted financial sanctions - freezing of any operations (transactions) and (or) funds of individuals, legal entities, groups and organizations in respect of which there is information about their participation in terrorist or extremist activities and proliferation of weapons of mass destruction, and (or) restriction of providing such individuals, groups and organizations with access (direct or indirect) to any funds or financial services;

18) electronic money transfer - an operation on transfer of funds (cash, non-cash, electronic money) from the sender to the recipient of the money transfer, carried out using payment systems;

19) transfer of virtual assets - an operation of transfer of virtual assets from the sender to the recipient, performed with the use of virtual asset wallet addresses.

2. Goal and Objectives of the Policy

2.1. The purpose of this Policy is to ensure human rights and freedoms, as well as to protect the national security and integrity of the financial system of the Kyrgyz Republic from criminal encroachment.

2.2. The objectives of this Policy are:

2.2.1. Application of measures to counter financing of terrorist activities and legalization (laundering) of criminal proceeds;

2.2.2. prevention of financing of terrorist activities and legalization (laundering) of proceeds of crime;

2.2.3. preventing the Company's involvement in financing of terrorist activities and legalization (laundering) of proceeds of crime;

2.2.4. ensuring completeness and timeliness of submission to the financial intelligence unit of information provided for by the Law on Counteraction;

2.2.5. application of effective procedures for assessment of risks related to financing of terrorist activities and legalization (laundering) of proceeds of crime;

2.2.6. ensuring the implementation and compliance of all employees of the Company with this Policy, taking into account the following requirements:

- participation in the process of implementation of internal control for the purposes of countering the financing of terrorist activities and legalization (laundering) of criminal proceeds of all employees regardless of their position within their competence,

- observance of commercial secrecy and confidentiality of information obtained in the process of internal control to counteract the financing of terrorist activities and legalization (laundering) of proceeds of crime,

- exclusion of participation of the Company's employees in the financing of terrorist activities and legalization (laundering) of proceeds of crime,

- maintaining confidentiality of information on the Company's internal documents developed for the purposes of countering the financing of terrorist activities and money laundering,

- professional development of the Company's employees in the field of countering the financing of terrorist activities and money laundering.

3. Internal control service

3.1. Internal control means the Company's activities to identify transactions subject to mandatory control and other transactions with cash or other property related to the financing of terrorist activities and legalization (laundering) of proceeds of crime.

3.2. The Company shall establish or determine the internal control service, taking into account the peculiarities of its activities, staffing, client base and risk level.

3.3. The head and employees of the internal control service shall be appointed and dismissed by order of the General Director.

The head of the internal control service reports directly to the CEO. Employees of the internal control service report directly to the head of the internal control service.

3.4. When applying for a job in the internal control service, candidates are subject to the following requirements:

- higher education;

- knowledge of the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds,

- knowledge of the risks specific to the activities of a financial institution;

- no criminal record;

- absence from national and international lists of wanted persons and lists of individuals and legal entities, groups and organizations in respect of which there is information about participation in terrorist and extremist activities, proliferation of weapons of mass destruction and legalization (laundering) of criminal proceeds.

3.5. The internal control service performs the following functions:

3.5.1. development of draft internal control programs and other internal documents in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds, including risk assessment methodologies and risk management procedures;

3.5.2. organization of the implementation of internal control programs;

3.5.3. monitoring of proper verification of the client and other participants in operations (transactions);

3.5.4. monitoring and analysis of the client's operations (transactions);

3.5.5. making a decision on recognizing an operation (transaction) as suspicious and sending a report on a suspicious operation (transaction) to the financial intelligence unit;

3.5.6. submission to the financial intelligence unit of reports on operations (transactions) subject to control and reporting in accordance with the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds;

3.5.7. providing assistance to authorized representatives of the inspection bodies when they conduct an audit of the Company's activities on compliance with the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds.

3.6. The internal control service has the right to:

3.6.1. receive the necessary administrative and accounting documents of the Company;

3.6.2. to gain access to databases of clients and beneficial owners formed in the Company;

3.6.3. receive and make copies of necessary documents, electronic files and records stored in the Company's information systems;

3.6.4. give temporary instructions regarding the conduct of the operation (transaction), including instructions on suspending the operation (transaction) and freezing the operation (transaction) and (or) funds;

3.6.5. perform other actions in accordance with the Company's internal documents.

3.7. The internal control service is obliged to:

3.7.1. ensure the safety and return of the Company's received documents;

3.7.2. to respect the confidentiality of information obtained in the exercise of their functions and not to disclose information about the transfer of information to the financial intelligence unit;

3.7.3. perform other actions in accordance with the Company's internal documents.

3.8. The Company's employees assist the internal control service in carrying out its functions in accordance with this Policy.

3.9. The Company's employees, who have become aware of the facts of violations of the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds committed in the Company, shall, within one business day, bring these facts in writing to the attention of their immediate supervisor and the internal control service.

4. Customer due diligence

4.1. The Company is obliged to apply the following measures of due diligence to all its clients:

4.1.1. identify and verify the client, including collecting and verifying personal information and identification documents, as well as comparing the information and documents obtained with public records and databases to confirm accuracy;

4.1.2. to receive information about the purpose and intended nature of the Client's business relationship;

4.1.3. identify the beneficial owner and take accessible and reasonable measures to verify the beneficial owner;

4.1.4. document the information obtained as a result of identification and verification of the client and the beneficial owner;

4.1.5. to check the client for the presence or absence in the Sanctions lists, as well as in the  List of persons, groups, organizations, in respect of which there is information about their participation in the legalization (laundering) of criminal proceeds;

4.1.6. to keep and update information and documents about the client's activities and financial situation, as well as information and documents obtained as a result of due diligence of the client;

4.1.7. conduct an ongoing due diligence of the client throughout the entire period of business relations with the client and analyze the compliance of operations (transactions) conducted by the client with available information about the content of his activities, financial situation and source of funds, as well as the nature of the risks of financing terrorist activities and the legalization (laundering) of criminal proceeds;

4.1.8. perform AML-verification of the crypto wallet address provided by the client and its transactions.

4.2. If a trusted person acts on behalf of the client, the Company is obliged to identify and verify him, verify the relevant authority of such person, and document the information received.

4.3. The Company applies the following additional measures of due diligence of the client in relation to public officials:

4.3.1. uses a risk management system to determine whether the client or the beneficial owner is a public official;

4.3.2. establishes the source of origin of funds or other property of a public official;

4.3.3. conducts continuous and in-depth monitoring of business relationships, including transactions carried out by a public official, in accordance with the procedure established for high-risk clients.

The Company applies the additional measures of due diligence of the client specified in this paragraph of the Policy also in relation to family members and close persons (close relatives, business partners and official representatives) of a public official, as well as in relation to other high-risk clients.

4.4. Clients are obliged to provide the Company with the requested information and (or) documents for conducting due diligence of the client no later than 10 (ten) business days from the date of receipt of such request.

4.5. If the Client fails to provide the information and/or documents necessary for conducting a proper audit of the client, the Company makes one of the following decisions:

1) does not establish business relations with the client (refuses to accept service);

2) suspends or terminates the established business relationship with the client (denial of service) and terminates the concluded contract with the client;

3) does not perform an operation (transaction).

When making a decision in this case, the Company is obliged to send a corresponding message to the financial intelligence unit within one business day from the date of making such a decision.

4.6. If, during the establishment of a business relationship or during a business relationship with a client, or during one-time transactions (transactions), the Company suspects that the transactions (transactions) are related to the financing of terrorist activities and the legalization (laundering) of criminal proceeds, the Company has the right to apply the following measures:

1) to identify and verify the client and the beneficial owner, regardless of any exceptions or established thresholds;

2) conduct a comprehensive analysis of the business relationship or operation (transaction) and decide whether to recognize the business relationship or operation (transaction) as suspicious;

3) suspend a suspicious operation (transaction) for up to 5 business days and, within five hours from the moment the operation (transaction) is recognized as suspicious in accordance with the established procedure, send a report on the suspicious operation (transaction) to the financial intelligence unit;

4) suspend or terminate business relations with the client.

5. Cases of due diligence of the client

5.1. The Company conducts a proper verification of the client (identifies and verifies the client) in any of the following cases:

5.1.1. when establishing a business relationship;

5.1.2. when performing a one-time transaction (transaction) or several interrelated one-time transactions (transactions) made within 1 (one) month for an amount equal to or exceeding 1,000,000 KGS or equivalent in foreign currency;

5.1.3. when making a one-time electronic money transfer or performing an operation (transaction) with virtual assets in the amount equal to or exceeding 100,000 KGS or the equivalent in a foreign currency;

5.1.4. if there is a suspicion of financing terrorist activities and legalizing (laundering) criminal proceeds, regardless of the client's status (permanent or one-time) or any exceptions, or regardless of the threshold amount of the transaction (transaction);

5.1.5. upon revealing the facts of unreliability or insufficiency of previously received information about the client.

5.2. When performing a one-time transaction (transaction) or several interrelated one-time transactions (transactions) in the amount of 100,000 KGS to 1,000,000 KGS or equivalent in foreign currency, the client's identity is established on the basis of an identity document, the client is checked for presence or absence in the Sanctions lists and in the List of persons, groups and organizations, in relation to who have information about their involvement in the legalization (laundering) of criminal proceeds.

5.3. When making a one-time electronic money transfer or transfer of virtual assets in the amount of 100,000 KGS to 1,000,000 KGS or the equivalent in foreign currency/virtual asset, the following standards must be observed. The Company is obliged to:

- generate information about the sender / recipient of an electronic money transfer / virtual assets (in particular, the surname, first name and patronymic of the sender - an individual or the name of the sender - a legal entity, the account number of the sender / recipient or the address of the electronic wallet, the passport data of the sender / recipient - an individual or the taxpayer identification number, or the code of the sender's foreign organization/the recipient is a legal entity);
получателя — юридического лица);

- check the sender/recipient of the money transfer/ virtual assets for the presence or absence in the Sanctions lists and the List of individuals, groups and organizations for which there is information about their participation in the legalization (laundering) of criminal proceeds;

When making a one-time electronic money transfer or transfer of virtual assets specified in this paragraph of the Policy, the questionnaire of the client and the beneficial owner is not filled in.

5.4. Customer due diligence measures are applied to new and existing customers, taking into account the customer's previous due diligence and the customer's risk level.

6. Identification and verification of the client

6.1. The Company is obliged to identify the client.

Identification of the client is performed by filling out the questionnaire of the individual client or the questionnaire of the legal entity client according to the forms approved by the order of the General Director of the Company.

The client's questionnaires are filled out and stored electronically in the Company's electronic database. When transferring the questionnaire data to paper, it is certified by the signature of the responsible employee of the Company.

The client's questionnaires are updated in the following cases:

- modification of the client documentation (the documents on the basis of which the verification was carried out);

- submission by the client or discovery by the Company of new information on the client's questionnaire and the questionnaire of the beneficial owner;

- the presence of reasonable grounds for the lack of information on an existing client;

- expiration of the questionnaire update period.

Deadlines for updating the information provided in the client's questionnaires and copies of documents received during due diligence of the client:

- for the client and the beneficiary owner with a high level of risk - at least once every three months;

- they are updated at least once a year for the client and the beneficial owner with a low level of risk.

6.2. When identifying the client, the Company establishes the purpose and intended nature of the business relationship with the client.

6.3. The Company is obliged to verify the client by verifying the accuracy of the information provided in the questionnaire of the individual client or the questionnaire of the legal entity client, using information and documents received from the client and from reliable sources.

6.4. To verify the identity of an individual client, the Company uses one of the following identity documents: passport, ID card, or driver's license, and also establishes the following information: address of residence (registration) or place of stay, taxpayer identification number (if any), as well as other information, which allows you to confirm the specified information.

6.5. For the verification of the client, a legal entity, the Company uses the following documents:

- the decision of the founder(s) on the establishment of a legal entity;

- the charter and the founding agreement (if provided for by the legislation of the Kyrgyz Republic);

- certificate of state registration (re-registration) of a legal entity;

- amendments (additions) to the constituent documents (decision, charter, founding agreement) - upon re-registration of a legal entity;

- a document confirming registration with the tax authority;

- documents confirming the powers of persons entitled to the first and second signatures in a card with signature samples and a seal impression (decisions of governing bodies, orders, powers of attorney);

- licenses for the right to conduct business (if any).

6.6. When verifying the client, the Company uses the original documents valid on the date of their presentation, or their duly certified copies.

If only a part of the document is relevant to the client's verification, a notarized extract from it may be submitted.

If a copy of the documents is submitted, the Company requires the original documents to be submitted for review and reconciliation.

6.7. If the documents are drawn up in whole or in part in a foreign language, the Company requires the client to translate the document into the state or official language certified by a notary.

6.8. Documents issued by government agencies of foreign countries confirming the status of non-resident legal entities are accepted by the Company in case of their legalization (apostille) in accordance with the Instructions on the procedure and conditions for affixing the apostille, approved by Resolution No. 283 of the Government of the Kyrgyz Republic dated November 18, 2010.

These documents may be submitted without their legalization (apostille) in cases stipulated by international treaties that have entered into force in accordance with the procedure established by law, to which the Kyrgyz Republic is a party.

6.9. When verifying the client, the Company is also entitled to use additional (auxiliary) information obtained from reliable sources.

6.10. In case of changes in the information contained in the questionnaires of the client and the beneficial owner, the client/beneficial owner  is obliged to provide the Company with updated information and documents no later than five working days from the date of the changes. The Company enters updated information into the questionnaires of the client and (or) the beneficial owner, within one business day from the date of receipt of the specified information.

6.11. The Client or the client's representative (the client's proxy) must, in accordance with the established form, consent to the collection and processing of personal data, including for the purpose of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds. The consent of the subject must be expressed in writing on paper or in the form of an electronic document signed with an electronic signature.

7. Identification and verification of the beneficial owner

7.1. The Company is obliged to identify the beneficial owner.

The beneficial owner is identified by filling out the beneficial owner's questionnaire in the form approved by the order of the General Director of the Company.

7.2. The beneficial owner's questionnaire is filled out in relation to the beneficial owner of new and existing clients.

7.3. If there are no beneficial owners who directly or indirectly (through third parties) own more than 25% of the shares (shares), or there are doubts about the size of the beneficial owner's share (shares), or the beneficial owner has not been identified as a result of the identification of the beneficial owner of the client, a legal entity, then an individual may be recognized as such, which has the ability to control the client's actions - a legal entity at the expense of positions held in the structure of the legal entity (responsible for strategic decision-making, exercises executive control, and makes decisions on financial matters). In this case, the questionnaire of the beneficial owner is filled in for this person. At the same time, the identification data of the known beneficial owners must be recorded.

7.4. If the beneficial owner of the client is several individuals, each with a share (shares) of more than 25%, then the questionnaire is filled out for each beneficial owner.

7.5. If the owner of a share (share) of more than 25% is a legal entity, it is necessary to find out and specify the specific individual who ultimately directly or indirectly (through third parties) owns (has a predominant participation of more than 25% in the capital) a legal entity or has the ability to control the actions of this legal entity.

In this case, it is necessary to attach to the questionnaire of the beneficial owner a scheme of the ownership (management) structure of the client - a legal entity, which provides for intermediate legal entities, up to the final owners - individuals, directly or indirectly (through third parties) owning more than 25% of shares (shares), and the degree of relationship between the founders - legal entities and the beneficial owner.

7.6. The Company is obliged to apply reasonable measures to verify the beneficial owner using the documents specified in paragraphs 6.4 – 6.5 of this Policy, or their duly certified copies, and (or) information obtained from reliable sources allowing to identify the beneficial owner.

8. The procedure for assessing the risk of the client's transactions related to the financing of terrorist activities and the legalization (laundering) of criminal proceeds

8.1. When conducting due diligence of the client, the Company's internal control service classifies its clients based on the information and documents available to it, taking into account the risk criteria (high and low) and records the risk level with justification for the risk assessment.

8.2. To assess the risk, the internal control service uses typical criteria for assessing high and low risks established by the financial intelligence unit.

8.3. When assessing risks, clients are classified according to the following degrees (levels) of risk:

- high risk,

- low risk.

8.4. The Company has the right to develop and apply criteria of average risks.

8.5. If the client and/or the transaction (transaction) meet at least one of the high risk criteria established by the financial intelligence unit, the risk level is assessed as high.

8.6. Depending on the assignment of the degree (level) of risk to the client, the Company's internal control service applies enhanced or simplified measures of due diligence of the client, using risk-baseda focused approach.

8.7. In case of identification of a high risk, the Company applies the following enhanced measures of due diligence of the client:

8.7.1. collection of additional identification information and documents regarding the client from accessible and reliable sources of information, as well as the use of this information in assessing the risk associated with the client;

8.7.2. collecting additional information about the client and the beneficial owner in order to better understand the risk of possible involvement of such client and beneficial owner in criminal activities;

8.7.3. request additional information from the client regarding the purpose and intended nature of the business relationship, as well as the source of the Client's funds;

8.7.4. verification of the sources of the client's funds used in the framework of establishing business relations in order to ensure that the funds are not proceeds of criminal activity;

8.7.5. regular updating of the identification data of the client and the beneficial owner using a risk-based approach;

8.7.6. request from the client for additional information explaining the reason or the economic meaning of the planned or conducted operations (transactions);

8.7.7. obtaining permission to establish or continue business relations with a client from the executive body or from one of the members of the executive body responsible for managing the Company's day-to-day operations;

8.7.8. implementation of enhanced monitoring of business relations through daily monitoring of operations (transactions), information analysis, consideration and accounting of funds allocation, including in manual mode, in order to identify signs of suspicious transactions (transactions) and transactions (transactions) that do not have obvious economic sense or obvious legitimate purpose, as well as communicating the results of monitoring to the information of the Internal Control Service and the executive body responsible for managing the Company's day-to-day operations;

8.7.9. an offer to conduct an operation (transaction) through a bank account, if the operation (transaction) is planned to be conducted without opening a bank account.

At the same time, the Company documents the need to apply enhanced due diligence measures to effectively manage and/or reduce risks.

8.8. Enhanced customer due diligence measures specified in clause 8.7 of this Policy are applied to individuals or legal entities from high-risk countries. The list of high-risk countries is established by the financial intelligence unit.

8.9. If a low risk is established, the Company applies the following simplified due diligence measures for the client:

8.9.1. obtaining general information about the purpose and intended nature of the business relationship;

8.9.2. verification of the client and the beneficial owner after establishing a business relationship;

8.9.3. reducing the frequency of updating the identification data of the client and the beneficial owner;

8.9.4. monitoring of the client's operations (transactions) in an abbreviated form, using an automated system for checking operations (transactions) based on a limit determined by the Company.

8.10. The Company does not apply simplified measures of due diligence of the client if there are suspicions of financing terrorist activities and legalizing (laundering) criminal proceeds.

9. Procedure for suspending an operation (transaction), freezing and unfreezing an operation (transaction) and (or) funds, providing access to frozen funds and managing frozen funds

9.1. If an individual or legal entity, the client, an authorized representative of the client, the beneficial owner and the client's counterparty are included in the List of persons, groups, organizations in respect of which there is information about their participation in the legalization (laundering) of criminal proceeds (hereinafter referred to as - an identified person), the Company is obliged to immediately suspend the operation (transaction) of the identified person without prior notification to the identified person, as well as to inform the financial intelligence authority within three hours from the moment of suspension of the operation (transaction) in accordance with the procedure established by clause 9.14 of this Policy.

9.2. In case of suspension of an operation (transaction), the Company verifies the presence or absence of funds of an identified person in its custody or management, and if available, sends a notification about this to the financial intelligence unit within three hours in accordance with the procedure established by clause 9.14 of this Policy.

9.3. Operations (transactions) are suspended until the financial intelligence unit makes a decision to seize property in accordance with the criminal procedure legislation of the Kyrgyz Republic.

The suspension of an operation (transaction) must not exceed two months from the date of suspension of the operation (transaction), during which a decision must be made to seize the property.

The financial intelligence unit sends a letter to the Company with information on the adoption or non-adoption of a decision to seize property in accordance with the criminal procedure legislation of the Kyrgyz Republic, within one business day from the date of receipt of a certified copy of this decision.

In case of failure to make a decision to seize the property, the suspended operation (transaction) is carried out on the basis of an order from the financial intelligence unit. This order is accepted within 14 working days from the expiration date of the suspension of the operation (transaction) on the basis of a written response from the relevant law enforcement agency, national security agency, prosecutor's Office of the Kyrgyz Republic or the competent authority of a foreign state.

9.4. If an individual and a legal entity, a group, an organization, a client, an authorized representative of the client, the beneficial owner and the client's counterparty (hereinafter referred to as the identified person) are included in the Sanctions lists, the operations (transactions) and (or) funds of the identified person are frozen indefinitely.

9.5. Subject to freezing:

- any funds owned or controlled by individuals, groups, organizations included in the Sanctions lists;

- funds that are fully or jointly owned, directly or indirectly (through third parties) owned or controlled by individuals, groups, organizations included in the Sanctions lists;

- funds received or produced through the use of funds that are fully or jointly owned, directly or indirectly (through third parties) owned or controlled by individuals, groups, organizations included in the Sanctions lists;

- funds of individuals, groups, organizations acting on behalf or at the direction of individuals, groups, organizations included in the Sanctions lists;

- funds intended to finance terrorist and extremist activities, terrorists and extremists, terrorist and extremist organizations, or persons distributing weapons of mass destruction;

- the means defined in the relevant resolutions of the UN Security Council.

9.6. The Company shall send a notification on the freezing of the operation (transaction) and (or) funds to the financial intelligence unit within three hours from the moment of freezing of the operation (transaction) and (or) funds in accordance with the procedure established by clause 9.14 of this Policy.

9.7. In case of freezing of an operation (transaction) and (or) funds, the Company verifies the presence or absence of other funds of a person in its custody or management, and if available freezes these funds and within three hours sends a message about this to the financial intelligence unit in accordance with the procedure established by clause 9.14 of this Policy.

9.8. Individuals and legal entities, groups and organizations included in the Sanctions lists are provided with access to frozen funds for the following purposes:

- payment for rental housing and utilities;

- repayment of mortgage and other loans;

- payment of taxes and insurance premiums;

- payment of fees, commissions or fees for the current storage or maintenance of bank accounts and frozen funds;

- food purchase;

- purchase of medicines;

- payment for medical services (treatment);

- payment for legal services (fee);

- receiving state benefits.

- other extraordinary expenses.

The decision on granting access to frozen funds is made by the financial intelligence unit.

9.9. Frozen funds remain in the ownership of an individual or legal entity, group, and organization that owned or had a stake in these funds at the time of freezing, but at the same time they come under the control of the financial intelligence unit before they are unfrozen.

9.10. Frozen funds, based on the instructions of the financial intelligence unit, are placed or stored in a special account (or in a vault) opened by an individual and a legal entity performing an operation (transaction).

9.11. Replenishment of frozen funds is allowed at the expense of interest or other income related to these funds, or at the expense of payments or payments under contracts, agreements or obligations that arose before the date of funds freezing. At the same time, such interest, other receipts and payments should be frozen.

9.12. Unfreezing of an operation (transaction) and (or) funds is carried out only on the basis of a decision of the financial intelligence unit.

9.13. The basis for unfreezing an operation (transaction) and (or) funds is the exclusion of an individual or legal entity, group or organization from the Sanctions lists.

If a decision is made to exclude an individual or legal entity, group, or organization from the Sanctions lists and the relevant information is published on the official website of the financial intelligence unit, the financial intelligence unit issues an order within one business day to unfreeze the operation (transaction) and (or) funds, indicating a specific individual or legal entity, group, and organizations.

Within one business day, the financial intelligence unit sends to the Company by fax or courier a certified copy of the financial intelligence agency's order to unfreeze the operation (transaction) and (or) funds.

Having received an order from the financial intelligence unit to unfreeze the operation (transaction) and (or) funds, the Company unfreezes the funds within one working day and reports on the measures taken to the financial intelligence unit.

9.14. The form of notification to the financial intelligence unit on the suspension of an operation (transaction), freezing of an operation (transaction) and (or) funds is established by the financial intelligence unit.

The message is sent to the financial intelligence unit in electronic form via electronic communication channels using an electronic signature determined by the financial intelligence unit. Subsequently, the original message signed by the General Director of the Company is sent to the financial intelligence unit by fax or courier.

9.15. The Company, its managers and employees must not disclose information about sending a message to the financial intelligence unit about the suspension of an operation (transaction), freezing of an operation (transaction) and (or) funds.

10. Transactions (transactions) subject to control and reporting

10.1. The Company forms and sends a report on a suspicious transaction (transaction) to the financial intelligence unit in the following cases:

- if there is suspicion or sufficient reason to suspect that the funds are proceeds of crime, including predicate crimes, or are related to the legalization (laundering) of criminal proceeds;

- if there is suspicion or sufficient reason to suspect that the funds are related to the financing of:

a) terrorists and extremists;

b) terrorist and extremist organizations (groups);

c) terrorist and extremist activities;

d) organized groups or criminal communities;

e) proliferation of weapons of mass destruction.

A report on a suspicious transaction (transaction), including a report on an attempt to commit a suspicious transaction (transaction), is sent regardless of the amount of the transaction (transaction) performed or being performed within five hours from the moment the transaction (transaction) is recognized as suspicious in accordance with the established procedure.

10.2. The Company submits to the financial intelligence unit a report on transactions with individuals or legal entities from high-risk countries (individuals or legal entities registered or operating in high-risk countries), regardless of the amount of the transaction (transaction).

A report on an operation (transaction) with individuals or legal entities from high-risk countries is submitted to the financial intelligence unit within two working days from the date of its commission.

10.3. Transactions (transactions) committed by an individual who has served a sentence for carrying out (committing) the legalization (laundering) of criminal proceeds, terrorist activities, extremist activities, proliferation of weapons of mass destruction, creation and leadership of an organized group or criminal community to commit crimes or participate in this group or community, or providing other assistance to this group or the community, as well as for financing such criminal activities, They are subject to mandatory monitoring to detect and prevent the re-commission of criminal activity.

The Company is obliged to submit to the financial intelligence unit a report on transactions made by an individual who has served a sentence for criminal activity within two working days from the date of their commission.

10.4. The Company is obliged to submit a report on transactions (transactions) with cash and non-cash funds in an amount equal to or exceeding the threshold amount.

A report on an operation (transaction) with cash and non-cash funds is submitted to the financial intelligence unit within three working days from the date of its commission.

10.5. Specified in paragraphs 10.1-10.4 of this Policy, messages are sent no later than 16:00 on the current day of the electronic message formation.

11. 11. Storage of information and documents

11.1. Общество хранит следующие сведения и документы:

- information, business correspondence and copies of documents, including questionnaires of the client and the beneficial owner, obtained as a result of due diligence of the client, for at least five years after termination of business relations with the client, account closure or one-time transaction (transaction) with the client;

- information and documents on all operations (transactions) performed - at least five years after the completion of the operation (transaction);

- conclusions or certificates on the analysis of transactions (transactions) - at least five years after the completion of the transaction (transaction);

- information and documents provided for by the legislation of the Kyrgyz Republic in the field of countering the financing of criminal activities and the legalization (laundering) of criminal proceeds, for at least five years after termination of business relations with the client, closing of the account or conducting a one-time transaction with the client;

- information about the sender and recipient of an electronic money transfer or virtual asset transfer, for at least five years from the date of completion of the transaction or termination of business relations with the client or account closure.

11.2. The Company submits the information and documents specified in clause 11.1 of this Policy:

- the financial intelligence unit and the relevant auditing body;

- law enforcement agencies, national security agencies, prosecutor's offices of the Kyrgyz Republic in accordance with the criminal procedure legislation of the Kyrgyz Republic.

12. Personnel training procedure

12.1. Basic training.

12.1.1.The Company develops a basic training procedure for personnel on countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds and a training plan.

12.1.2. The basic training of the Company's employees is carried out in the following forms:

1) introductory (primary) training;

2) Unscheduled (targeted) training;

3) planned training.

12.1.3. Introductory (primary) training is conducted in order to familiarize with the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds and the internal documents of the Company on countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds.

Introductory (primary) training is conducted upon admission or transfer to the internal control service. After three months from the date of admission or transfer, the employee's level of knowledge in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is assessed.

12.1.4. Unscheduled (targeted) training on countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is conducted in the following cases:

- in case of changes in existing or entry into force of new regulatory legal acts of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds;

- when introducing new or changing existing internal control programs to counter the financing of terrorist activities and the legalization (laundering) of criminal proceeds;

- when transferring an employee to another permanent job within the Company's divisions, in the event that his existing knowledge in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is insufficient to perform his functions;

- when assigning an employee to work in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds that is not conditional on an employment contract concluded with him, when this does not entail a change in the terms of this contract.

12.1.5. Scheduled training of the Company's employees is carried out regularly, but at least once a year.

Routine training in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is conducted through the participation of employees in conferences, seminars and other training events conducted by educational organizations in accordance with the training programs of educational organizations.

12.1.6. The examination of employees' knowledge in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is carried out at least once a year in accordance with the Company's training plan.

12.2. Additional professional education (advanced training and professional retraining).

12.2.1. The Company annually develops a schedule for advanced training and professional retraining of its personnel in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds, taking into account the requirements of the legislation of the Kyrgyz Republic in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds, as well as the specifics of its activities, and no later than December 15 of this year They send this schedule to the financial intelligence unit.

12.2.2. The Company regularly, but at least once a year (in accordance with the schedule), sends employees of the internal control service and other employees working directly with clients (at their discretion), including the Company's managers, to an educational organization for advanced training and professional retraining.

12.3. Accounting for training.

12.3.1. The Company keeps records of employees' training in the relevant journal, including in electronic format.

12.3.2. The list of personnel trained in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds is sent in writing and electronically to the financial intelligence unit of the Kyrgyz Republic no later than December 25 of this year in order to centrally record trained personnel and create an appropriate database.

13. Responsibility of the Company

13.1. The Company, its managers and officials (employees) are not responsible for sending a report on a suspicious transaction to the financial intelligence unit and for damage caused to individuals and legal entities in connection with their proper performance of duties provided for by the legislation of the Kyrgyz Republic in the field of countering the financing of criminal activities and legalization (laundering) criminal proceeds.

13.2. Freezing of funds and (or) operations (transactions), suspension of operations (transactions), refusal to establish business relations or open a bank account (deposit) or refusal to conduct an operation (transaction), as well as suspension or termination of business relations, termination of the contract with the client shall not entail civil or criminal liability. other liability, if the specified actions were committed in accordance with the legislation of the Kyrgyz Republic in the field of countering the financing of criminal activities and the legalization (laundering) of criminal proceeds.

14. Other provisions

14.1. Employees of the Company, including the management and former employees, as well as persons who have concluded civil law contracts with the Company, are prohibited from disclosing, transferring or otherwise using confidential information that has become known to them in connection with the performance of their duties during the period of validity, as well as after termination of the employment relationship or the validity of the contract. in the field of countering the financing of terrorist activities and the legalization (laundering) of criminal proceeds, with the exception of cases provided for by the legislation of the Kyrgyz Republic.

14.2. This Policy is based on 2 (two) languages – Russian and English. Russians Russian-language Policy will take precedence in case of contradictions between the Russian and English versions of the Policy.