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AML/CFT Policy

Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Policy of the JETUP Platform

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1. Introduction

1.1. Purpose of the Policy

This Anti-Money Laundering and Counter-Financing of Terrorism Policy (hereinafter - "AML/CFT Policy") has been developed to ensure compliance of the JETUP platform (hereinafter - "Platform") activities with the requirements of Georgian legislation and international standards in the field of anti-money laundering and counter-financing of terrorism.

1.2. Scope of Application

This AML/CFT Policy applies to all employees, managers, partners, and users of the Platform. All persons associated with the Platform's activities are obliged to comply with the provisions of this Policy and facilitate its implementation.

1.3. Regulatory Framework

This AML/CFT Policy has been developed in accordance with:

  • The Law of Georgia "On Prevention of Illicit Income Legalization"

  • FATF (Financial Action Task Force) Recommendations

  • European Union Anti-Money Laundering Directives

  • Other applicable international standards and regulations

2. Key Principles and Commitments

2.1. Basic Principles

The JETUP Platform adheres to the following key principles in the field of AML/CFT:

  • Zero tolerance for money laundering and terrorism financing

  • Compliance with all applicable laws and regulations in the field of AML/CFT

  • Application of a risk-based approach when implementing AML/CFT measures

  • Ensuring transparency and honesty in all operations

  • Continuous improvement of AML/CFT systems and procedures

2.2. Basic Commitments

The JETUP Platform assumes the following commitments:

  • Implementation and maintenance of an effective internal control system in the field of AML/CFT

  • Conducting proper customer due diligence (KYC) before establishing business relationships and on a regular basis during service provision

  • Monitoring transactions and identifying suspicious activity

  • Timely informing authorized bodies about suspicious operations

  • Ensuring confidentiality of information related to AML/CFT

  • Regular training of employees on AML/CFT issues

  • Cooperation with regulatory and law enforcement agencies in countering money laundering and terrorism financing

2.3. Management Responsibility

The senior management of the JETUP Platform is responsible for:

  • Approval and periodic review of the AML/CFT Policy

  • Ensuring sufficient resources for the implementation of AML/CFT measures

  • Appointment of an AML/CFT officer

  • Regular monitoring of the effectiveness of AML/CFT measures

3. Customer Identification and Verification (KYC)

3.1. General Provisions

The JETUP Platform applies "Know Your Customer" (KYC) procedures to all users who wish to access the full functionality of the platform. KYC procedures are aimed at establishing and verifying users' identities, as well as assessing risks associated with their activities.

3.2. Verification Levels

The JETUP Platform uses a multi-level user verification system:

  • Basic level: required for registration on the platform and includes providing basic information (name, email, phone number)

  • Standard level: required for operations with limited amounts and includes providing additional personal information and documents confirming identity

  • Enhanced level: required for operations with large amounts and includes in-depth verification and provision of additional documents

3.3. Required Documents

Depending on the verification level, users may be required to provide the following documents:

  • Identity document (passport, ID card)

  • Proof of residence address (utility bill, bank statement)

  • Selfie with identity document

  • Additional documents for legal entities (certificate of registration, charter, information about beneficial owners)

3.4. Verification Procedure

  • The user provides the necessary documents through a secure communication channel

  • Platform employees check the authenticity and relevance of the provided documents

  • If necessary, additional verification is conducted using external data sources

  • Based on the verification results, a decision is made on verifying the user or requesting additional information

3.5. Information Update

The JETUP Platform regularly updates information about users:

  • Annually for users with a low risk level

  • Every 6 months for users with a medium risk level

  • Every 3 months for users with a high risk level

3.6. Service Refusal

The JETUP Platform reserves the right to refuse service or restrict access to its services to users who:

  • Have not provided the necessary information or documents

  • Have provided false information

  • Have a high risk from an AML/CFT perspective

4. Risk Assessment and Transaction Monitoring

4.1. Risk-Based Approach

The JETUP Platform applies a risk-based approach to assessing and managing AML/CFT risks. This allows for the effective allocation of resources and application of enhanced control measures where the risks are higher.

4.2. Risk Factors

The following factors are considered when assessing risks:

  • Geographic risk (country of origin/residence of the user)

  • Client risk (type of client, sphere of activity)

  • Product risk (type of services and products used)

  • Transaction risk (volume and nature of operations)

4.3. Risk Categories

Based on risk assessment, users are classified into the following categories:

  • Low risk

  • Medium risk

  • High risk

4.4. Enhanced Due Diligence Measures

For users with a high risk level, enhanced due diligence measures are applied, including:

  • More frequent updating of client information

  • Additional verification of sources of funds

  • Stricter transaction monitoring

  • Approval of operations at the senior management level

4.5. Transaction Monitoring

The JETUP Platform carries out continuous monitoring of users' transactions to identify suspicious activity. Monitoring includes:

  • Automated transaction screening based on predefined rules and algorithms

  • Analysis of unusual activity patterns

  • Comparison of transactions with the client's risk profile

  • Identification of operations exceeding established thresholds

4.6. Indicators of Suspicious Activity

Indicators of suspicious activity include:

  • Unusually large transactions

  • A series of small transactions that collectively constitute a large sum

  • Transactions that do not correspond to the client's usual activities

  • Frequent transfers of funds to high-risk countries

  • Attempts to bypass reporting thresholds

4.7. Investigation of Suspicious Activity

When suspicious activity is identified:

  • A thorough analysis of transactions and client profile is conducted

  • Additional information may be requested from the client if necessary

  • A decision is made on the need to file a report on a suspicious operation to the authorized body

4.8. Record Keeping

The JETUP Platform maintains detailed records of all risk assessments conducted, monitoring results, and investigations. These records are kept for at least 5 years and can be provided to authorized bodies upon request.

5. Staff Training and Internal Control

5.1. Training Program

The JETUP Platform implements a comprehensive AML/CFT training program for all employees. The purpose of the program is to ensure that employees understand their responsibilities within the AML/CFT framework and develop skills in identifying suspicious activity.

5.2. Training Content

The training program includes the following topics:

  • Overview of AML/CFT legislation

  • JETUP Platform's AML/CFT policies and procedures

  • Customer identification and verification (KYC)

  • Risk assessment and transaction monitoring

  • Identification and reporting of suspicious activity

  • Sanctions for non-compliance with AML/CFT requirements

5.3. Training Frequency

  • Initial training: conducted for all new employees within the first month of work

  • Regular training: conducted for all employees at least once a year

  • Additional training: conducted when there are significant changes in legislation or AML/CFT procedures

5.4. AML/CFT Officer

The JETUP Platform appoints an AML/CFT officer who:

  • Exercises general control over compliance with the AML/CFT policy

  • Ensures timely updating of policies and procedures

  • Coordinates the staff training program

  • Interacts with regulatory bodies on AML/CFT issues

5.5. Internal Audit

The JETUP Platform conducts regular internal audits of the AML/CFT system to assess its effectiveness. The audit includes:

  • Verification of compliance with AML/CFT policies and procedures

  • Assessment of the effectiveness of customer identification and verification processes

  • Analysis of the effectiveness of the transaction monitoring system

  • Verification of the completeness and timeliness of staff training

5.6. Reporting

The results of internal audit and the overall effectiveness of the AML/CFT system are regularly reported to the senior management of the JETUP Platform.

5.7. Disciplinary Measures

Disciplinary measures, up to and including dismissal and, in case of serious violations, informing law enforcement agencies, are applied to employees who violate the requirements of the AML/CFT policy.

5.8. Confidentiality

All employees are required to maintain the confidentiality of information related to AML/CFT, including information about suspicious operations and ongoing investigations.

6. Data Storage, Policy Review, and Final Provisions

6.1. Data Storage

6.1.1. The JETUP Platform ensures the storage of all information related to AML/CFT, including:

  • Customer identification and verification data

  • Transaction records

  • Risk assessment results

  • Reports on suspicious activity

  • Results of internal audits and checks

6.1.2. The data retention period is at least 5 years from the date of termination of business relations with the client or completion of the operation.

6.1.3. All data is stored in a secure format in compliance with the requirements of legislation on personal data protection.

6.2. Policy Review

6.2.1. This AML/CFT Policy is subject to regular review and update:

  • At least once a year

  • When there are significant changes in legislation

  • When deficiencies are identified in current procedures

  • Upon recommendation of regulatory bodies

6.2.2. The AML/CFT officer is responsible for initiating and coordinating the policy review process.

6.2.3. All changes to the policy are approved by the senior management of the JETUP Platform.

6.3. Interaction with Regulatory Bodies

6.3.1. The JETUP Platform undertakes to:

  • Promptly provide information upon requests from authorized bodies

  • Cooperate during inspections and investigations

  • Respond promptly to prescriptions and recommendations of regulatory bodies

6.4. Conflict of Interest

6.4.1. All employees of the JETUP Platform are obliged to avoid situations that may lead to a conflict of interest in the field of AML/CFT.

6.4.2. In case of a potential conflict of interest, the employee is obliged to immediately report this to the AML/CFT officer.

6.5. Responsibility for Policy Violation

6.5.1. Violation of the provisions of this Policy may result in disciplinary measures, including dismissal, as well as civil or criminal liability in accordance with the laws of Georgia.

6.6. Final Provisions

6.6.1. This Policy comes into force from the moment of its approval by the senior management of the JETUP Platform.

6.6.2. All employees of the JETUP Platform are obliged to familiarize themselves with this Policy and comply with its provisions.

6.6.3. In case of contradictions between the provisions of this Policy and the requirements of Georgian legislation, the norms of current legislation apply.

Last updated: 01.05.2025

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