1.  Introduction

This Money Laundering and Terrorist Financing policy (“Policy”) applies to Analie Sarl with registered office at 36 Op der Tonn, Gonderange, L-6188, Luxembourg ("Analie", "we", "us" or "our").

We are committed to adherence to all relevant legislation enacted to combat money laundering and to the prevention of criminals from being able to use us to help them launder money, or to finance terrorism.

The purpose of the Policy is to lay down our internal practice, measures, procedures and controls relevant to the prevention of money laundering and terrorist financing.

2.  Definitions

“Beneficial Owner” means the natural person or natural persons, who ultimately own or control the Client and/or the natural person on whose behalf a transaction or activity is being conducted. The Beneficial Owner shall at least include:

(a) In the case of corporate entities:

  1. The natural person or natural persons, who ultimately own or control a legal entity through direct or indirect ownership or control of a sufficient percentage of the shares or voting rights or ownership interest in that entity. A shareholding of 25% or an ownership interest of more than 25% in the customer held by a natural person or by multiple corporate entities, which are under the control of the same natural person, shall be an indication of direct ownership.

  2. If, after having exhausted all possible means and provided there are no grounds for suspicion, no beneficial owner of a corporate entity can be identified, or if there is any doubt that the person(s) identified are the beneficial owner(s), then any natural person who holds the position of senior managing official of the Client will be treated as the beneficial owner.

(b) In the case of trusts or in the case of legal entities such as foundations, and legal arrangements similar to trusts:

  1. The settlor;

  2. The trustee(s);

  3. The protector, if any;

  4. The beneficiaries, or where the individuals benefiting from the legal arrangement or entity have yet to be determined, the class of persons in whose main interest the legal arrangement or entity is set up or operates;

  5. Any other natural person exercising ultimate control over the trust by means of direct or indirect ownership or by other means;

“Law” means the Luxembourg law of 25th March 2020 implementing EU directive 2018/8432 (the “5th AML Directive”) on the fight against money laundering and terrorism financing.

“Politically Exposed Persons (PEPs)” means the natural persons who have their place of residence in any European Union Member State or in third countries and who are or have been entrusted with prominent public functions and their immediate family members or persons known to be close associates of such persons.

3.  Main Objectives

The main objectives of our Money Laundering and Terrorist Financing policy is to:

  • Combat and prevent money laundering and terrorist financing and to take all the necessary preventive measures.

  • Prevent the misuse of Analie by anyone or anybody in illegitimate operations.

  • Determine the legal and administrative responsibilities of the Company and of all its employees related to anti-money laundering.

  • Report the suspicious operations which include the probable activities of the operations of money laundering and terrorist financing to the competent authorities.

  • Train all employees on the rules and internal procedures which have to be observed, the risks that they and we face and how they can encounter the risks of money laundering and terrorist financing.

 

4.  Scope of Application

This policy is applied to all activities, services, products and workplaces of the company.

5.  Company Commitment

Our commitment in respect of money laundering and terrorist financing is to:

  • Accept only those Clients whose identity can be established and verified.

  • Make every possible effort to know the identity of the Client and the Beneficiary Owner of the Client (i.e. the full name, the place and date of birth and verifying the identity by using valid "identification data"), in addition to the data and information available from trusted independent sources.

  • Apply a risk-based approach, and enhanced customer due diligence where required.

  • Provide periodic and appropriate AML / CTF training and information to all employees to increase their awareness using various methods.

  • Maintain records, which are appropriate to the nature and complexity of the Client and/or the Client’s business.

 

6.  Client Acceptance Policy

We apply a risk-based approach to client acceptance. Potential clients are assessed for:

  1. Client Risk - obtaining sufficient information to ensure that you fully understand who the client is and the risks posed by them, including politically exposed person (PEP) risk and sanction risk;

  2. Transaction Risk - reviewing the proposed engagement to ensure that it makes sense for the client and does not represent a high risk of money laundering; and

  3. Geographical Risk - understanding that not all countries carry the same risk and being aware of the location of the client and any environments in which they operate.

Clients are only accepted after a) a satisfactory risk assessment has been completed and b) after all relevant supporting documentation and data have been collected.

7.  Client Due Diligence

We conduct client due diligence in the following circumstances:

  • When accepting a new Client

  • When there is a suspicion of money laundering or terrorist financing

  • When identification documents that Clients have provided are unreliable or inadequate

Clients are also screened against a dynamic global database of Sanctions, Watchlists and PEPs as well as for Adverse Media.

8.  Employees’ Obligations

Our employees are obligated to report, without delay, anything that comes to their attention in relation to Clients of transactions for which there is a any suspicion that are related to money laundering or terrorist financing.

 

9.  Changes to our Money Laundering and Terrorist Financing policy

We may modify or amend this Policy from time to time at our discretion. When we make changes to this Policy, we will amend the revision date at the top of this page, and such modified or amended Money Laundering and Terrorist Financing policy shall be effective as of that revision date. We encourage you to periodically review this Money Laundering and Terrorist Financing policy to be informed about the steps that we are taking to prevent money laundering and terrorist financing.