Anti-money laundering and customer identification policies

1. Introduction.

Quantum Leap Company LLC (hereinafter "QLC") is committed to preventing money laundering and terrorist financing in its business practices and transactions. Therefore, “Identify your customer” procedures have been established to combat such crimes. These procedures allow us to identify all the people and organizations with which we deal, understand the legitimacy of our business relationships and identify and react to unusual activities or suspicious.

Money laundering is the process by which the origin of funds generated by the exercise of some illegal activities is hidden (the most common are drug or narcotics trafficking, arms smuggling, corruption, fraud, trafficking of people, tax evasion and terrorism). The objective of the operation, which is usually carried out at several levels, is to make funds or assets obtained through illicit activities appear as the result of legal activities and circulate smoothly in the financial system.

Stages of money laundering:

2. Objective.

Establish the parameters that QLC will observe to prevent and detect acts, situations and transactions that may involve resources of illicit origin or facilitate, assist or cooperate in any way in the commission of the crime of money laundering or the financing of terrorism.

To prevent money laundering, QLC does not accept or pay cash under any circumstances. The company reserves the right to suspend the operation of any client, which may be considered illegal or may be related to money laundering in the sole discretion of the company.

3. Scope.

This policy is applicable to all Collaborators related to the Company, including directors and managers, who are part of its organizational structure, as well as advisors, service providers or any third party hired by the QLC that is subject to any regime. money laundering prevention.

4. Company commitment.

QLC will always ensure that you are dealing with a real or legal person. Therefore, we carry out all necessary measures in accordance with applicable laws and regulations issued by competent authorities and international organizations. The anti-money laundering policy is carried out through the following measures: Know your customer and due diligence, monitoring customer activity and record keeping.

5. Customer identification and due diligence.

This process takes place before starting any type of relationship with the client. In this phase we ensure that satisfactory evidence of the client's identity is obtained, or other measures are taken that produce sufficient evidence of the identity of the client or counterparty. QLC also applies more rigorous scrutiny to clients residing in other countries, identified as having inadequate anti-money laundering regulations or who may pose a high risk for crime and corruption and in favor of beneficiaries who reside and whose funds are origin of the mentioned countries.

To support our customer identification policy and procedures, QLC has developed a questionnaire that we send to all our customers to collect relevant business information to identify money laundering risks. We require that the questionnaire be completed by all existing and new customers.

By collecting and reviewing information in completed KYC forms, QLC undertakes to:

If customers are considered high risk for any reason (for example, if they are on a sanctions list or engaging in unusual activities), we may:

6. VIdentity verification.

Proper account documentation and KYC procedures provide satisfaction and protection to QLC against unforeseen events and help establish the relationship in accordance with company policies. Obtaining maximum reliable information about the client is the basic principle. Staff should prudently ensure that all necessary documents have been obtained at the time of account opening.

Our company has the obligation to know its customers. This applies to all types of customers, regardless of who they are, their personal situation, or the type of account or service they require. Knowing your customer means:

All potential clients for accounts must be seen face to face or spoken to via a registered phone number and verified through other means such as social media contact. Account opening and client information forms must be completed, and any other interview notes must be obtained and retained in the client's file.

7. General principles of client identification.

QLC Compliance must verify each customer's credentials when an account is first opened. This applies to all account types.

All potential account holders must completely complete the questionnaire and provide the necessary documentary evidence of identity and financial information. If any column of any of the forms is not applicable it should be marked as N/A, no section should be left blank.

All additional information obtained during the interview about the client's background and financial situation must be recorded by the client and kept in his or her file.

8. RCarrying out the account opening and authorization procedures..

No account will be opened until the account opening and questionnaire have been completed and all documents have been received and reviewed for validity. For example:

If there are any suspicious circumstances surrounding the opening or operation of any account, the matter should be immediately reported to Compliance for further due diligence.

Establishing the identity of anyone wishing to do business with QLC is vital. All applicants are required to be satisfied that:

  • The person we are dealing with is who they say they are and resides at the address they have indicated.
  • The company we are dealing with is a legitimate business with a known address and represents legitimate owners.

    Therefore, when it comes to business accounts, it is necessary to verify the identity of the business entity and the key persons who will operate the account, as well as those who invest in or control the company.

    9. Client identification - Account opening documentation.

    For each type of client, we must obtain certain documentation and collect enough information so that we are certain that:

    Original identification documents must be viewed, photocopied and retained in the client's file.

    Make sure that the copies are clear and legible and that they are stamped, signed and dated to show that you have seen the originals. If there is any doubt about the legality or acceptability of any document, the compliance officer should be consulted immediately.

    The documents that will be requested from clients are the following

    Physical persons


    In the case of enhanced due diligence, the following documents will be requested for both an individual and companies:

    10. Procedures in which identification cannot be completed.

    Businesses in which all the required information cannot be obtained will be rejected. Exceptions will only be allowed by decision of the Compliance Area Manager, who will determine if there are genuine reasons why the information or documentation is not available. In cases where there are no valid explanations for the absence of information or documentation, the circumstances must be communicated as a possible suspicion

    11. Circumstances for declining.

    New relationships that do not appear legitimate should be rejected, including those where the applicant does not provide essential documentation or proof of identity and address.

    12. Maintain a record of open and closed accounts.

    Capital Operations will maintain a record of all open and closed accounts. The head of capital operations will send a monthly report of all open and closed accounts to Management. The record of open and closed accounts must be maintained for 5 years after the relationship ends.

    13. Directors of private companies.

    The director of the companies must confirm whether they are the main shareholders and, if not, the final beneficiaries of the company must be identified.

    KYC information is necessary to establish an expected pattern of activity and can help the Company

    14. Review and monitoring.

    a) Due diligence on clients in progress.

    It's not just potential customers who can put QLC at risk. Occasionally, clients may deliberately seek to create a degree of trust before using QLC for other purposes; Others may turn to crime due to a change in their personal circumstances. Therefore, some existing customers may be involved, deliberately or unintentionally, in violating rules and regulations. It is therefore vital that all staff are vigilant and that all unusual transactions by any customer are identified, discreetly investigated and, where there is a suspected breach of rules and regulations, a report is sent to the Head of Compliance.

    The basis of any control procedure lies in the initial collection of identifying and "know your customer" information.

    At the time of account opening, the nature of the business a customer expects to conduct should be determined and updated periodically. This will allow Compliance and staff to judge whether the customer's transactions are in line with expectations or whether unusual transactions are cause for concern and possible suspicion that criminal money may be involved. The initial period of any relationship with a new client presents the greatest vulnerability and therefore warrants additional monitoring procedures. Once the initial period (up to the first three months) has passed, continuous routine monitoring covering all transactions becomes the norm.

    b) Update knowledge, the client.

    Staff members must stay up to date on the client with reference to:

    Document customer brokerage habits and transaction patterns.

    15. Preservation of records/documents..

    Records must be retained to provide an audit trail and adequate evidence for law enforcement in their investigations. The minimum conservation periods that must be met are:

    16. Transaction monitoring.

    The most important safeguard against violating rules and regulations is the ability to detect suspicious transactions and take additional steps to prevent such transactions from recurring.