The policy of TWIM is not to enter into business relationships with criminals and/or terrorists, not to process transactions which result from criminal and/or terrorist activity and not to facilitate any transactions involving criminal and/or terrorist activity including the financing of terrorism. The Company undertakes to implement all policies and procedures necessary to prevent the money laundering and to comply with all applicable legislation in this regard.
TWIM Anti-Money Laundering Policy (hereinafter - the "AML Policy") is designated to prevent and mitigate possible risks of TWIM being involved in any kind of illegal activity.
Both international and local regulations require TWIM to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
AML Policy covers the following matters:
One of the international standards for preventing illegal activity is customer due diligence ("CDD"). According to CDD, TWIM establishes its own verification procedures within the standards of anti-money laundering and "Know Your Customer" frameworks.
TWIM's identity verification procedure requires the User to provide TWIM with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, TWIM reserves the right to collect User's identification information for the AML Policy purposes.
TWIM will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and TWIM reserves the right to investigate certain Users who have been determined to be risky or suspicious.
TWIM reserves the right to verify User's identity on an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, TWIM reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
The Compliance Officer is the person, duly authorized by TWIM, whose duty is to ensure the effective implementation and enforcement of the AML Policy. It is the Compliance Officer's responsibility to supervise all aspects of TWIM's anti-money laundering including but not limited to:
The Compliance Officer is entitled to interact with law enforcement, involved in the prevention of money laundering, terrorist financing, and other illegal activity.
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, TWIM relies on data analysis as a risk-assessment and suspicion detection tool. TWIM performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
With regard to the AML Policy, TWIM will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor Users' transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
TWIM, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, TWIM is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.