Regulatory Compliance and Transparency
This statement outlines the principles and practices that GraniteMark (hereinafter referred to as the "Company") strictly adheres to in its fight against money laundering (AML) and terrorism financing (CFT). As part of this initiative, the Company implements a range of measures to identify and prevent the legalization of funds obtained through criminal activities, in accordance with international standards and requirements in this field.
1. Identification and Verification
1.1. In accordance with AML and KYC (“Know Your Customer”) principles, the Company conducts client identification and verification based on provided documents and data at both the beginning of the relationship and throughout the provision of services.
1.2. Upon registration, the client provides identifying information, including full name, date of birth, place of residence, contact phone number, and email address.
1.3. After receiving the identifying information, the Company verifies the client by requesting appropriate documents.
- 1.3.1. To verify the client’s identity, a high-quality scanned copy or photo of the passport, driver’s license, or another government-issued identity document is required.
- 1.3.2. To confirm the client’s residential address, a high-quality scanned copy or photo of a utility bill or bank statement, no older than three months, is required.
1.4. Upon request from the Company, the client must provide a scanned copy or photo of both the front and back sides of their payment card. The front side must clearly display the cardholder’s full name, the card’s expiration date, and the first six and last four digits of the card number. The back side must clearly show the cardholder’s signature, with the CVC2/CVV2 code concealed.
2. Transaction Monitoring and Funds Handling Policy
2.1. To reduce the risk of money laundering and terrorism financing, the Company does not accept cash deposits and does not make cash withdrawals under any circumstances.
2.2. The Company reserves the right to reject the processing of a transaction at any stage if there is suspicion that the transaction is related to money laundering or other illegal activities.
2.3. In accordance with international legislation, the Company does not inform the client that their suspicious activity has been reported to the relevant authorities.
2.4. When making a deposit, the sender’s name must exactly match the name provided during account registration. Payments from third parties are not accepted.
2.5. The Company requires adherence to the standard deposit and withdrawal procedures. Withdrawals must be made to the same account and using the same method as the deposit. When withdrawing funds, the recipient’s name must exactly match the client’s details in the Company’s database. If the deposit was made via bank transfer, the funds may only be withdrawn in the same manner and to the same account at the same bank from which the deposit was made. If the deposit was made via an electronic payment system, the funds may only be withdrawn through the same system and to the same account from which the deposit was made.
2.6. In accordance with procedures to prevent the legalization of illegally obtained funds, withdrawals are only allowed in the currency in which the deposit was made.
2.7. The Company retains data on all transactions for five years after the termination of the client’s agreement.
3. AML Compliance and Staff Training
3.1. The Company appoints an employee responsible for ensuring compliance with anti-money laundering legislation. This employee is fully responsible for adhering to the CFT and AML policies, developing and implementing the Company’s AML program, as well as training staff in money laundering prevention, receiving, reviewing, and storing internal reports on suspicious activity.
3.2. All employees and managers of the Company undergo thorough background checks during the hiring process.
3.3. Employees who interact with clients and are involved in detecting and tracking crimes related to the legalization of illegally obtained funds undergo money laundering prevention training. Each new employee is provided with an AML training plan. This training includes professional preparation on identifying suspicious activity, preventing and detecting crimes related to money laundering and terrorism financing, as well as submitting the relevant reports.
3.4. The employee responsible for ensuring compliance with anti-money laundering legislation must receive reports of any violations of the Company’s AML policy, if any. If the employee responsible for AML compliance violates this policy, a report of such a violation must be submitted to the Company’s management.
4. AMENDMENTS TO THIS AML POLICY
The Company reserves the right to make changes to this AML Policy at any time and recommends reviewing it periodically. Continued use of the website’s services or visiting the website constitutes automatic acceptance of any amendments to this Policy.