02-AML-Policy

Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy of JetUP Platform

1. Introduction

1.1. Purpose of the Policy

This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the "AML/CFT Policy") has been developed to ensure compliance of the JetUP platform (hereinafter referred to as the "Platform") with Georgian legislation and international standards in the field of anti-money laundering and counter-terrorist financing.

1.2. Scope of Application

This AML/CFT Policy applies to all employees, officers, partners, and users of the Platform. All persons associated with the Platform's operations are required 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 the Prevention of Money Laundering"
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. Fundamental Principles

JetUP Platform adheres to the following key principles in the area of AML/CFT:

a) Zero tolerance for money laundering and terrorist financing

b) Compliance with all applicable AML/CFT laws and regulations

c) Implementation of a risk-based approach in AML/CFT measures

d) Ensuring transparency and integrity in all operations

e) Continuous improvement of AML/CFT systems and procedures

2.2. Core Commitments

JetUP Platform undertakes the following commitments:

a) Implementation and maintenance of an effective internal AML/CFT control system

b) Conducting proper customer due diligence (KYC) prior to establishing business relationships and on an ongoing basis

c) Transaction monitoring and suspicious activity detection

d) Timely reporting of suspicious transactions to authorized bodies

e) Ensuring confidentiality of AML/CFT-related information

f) Regular staff training on AML/CFT matters

g) Cooperation with regulatory and law enforcement authorities in combating money laundering and terrorist financing

2.3. Management Responsibility

The senior management of JetUP Platform is responsible for:

a) Approval and periodic review of the AML/CFT Policy

b) Ensuring sufficient resources for AML/CFT measure implementation

c) Appointment of an AML/CFT Compliance Officer

d) Regular monitoring of AML/CFT measures effectiveness

3. Customer Identification and Verification (KYC)

3.1. General Provisions

JetUP Platform implements Know Your Customer (KYC) procedures for all users seeking access to the Platform's full functionality. KYC procedures are designed to establish and verify user identity and assess risks associated with their activities.

3.2. Verification Levels

JetUP Platform employs a tiered verification system:

a) Basic Level:

Required for Platform registration
Includes provision of essential information (name, email, phone number)

b) Standard Level:

Required for transactions with limited amounts
Includes provision of additional personal information and identity verification documents

c) Enhanced Level:

Required for high-value transactions
Includes comprehensive due diligence and supplementary documentation

3.3. Required Documentation

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

a) Government-issued identification documents (passport, ID card)

b) Proof of residence (utility bills, bank statements)

c) Selfie with identity document

d) Additional documentation for legal entities:

Certificate of incorporation
Articles of association
Beneficial ownership information

3.4. Verification Procedure

The verification process consists of:

a) User submission of required documents through secure channels

b) Platform staff verification of document authenticity and validity

c) Additional verification through external data sources as necessary

d) Final determination of user verification status or request for supplementary information

3.5. Information Updates

JetUP Platform updates user information according to the following schedule:

a) Annually for low-risk users

b) Semi-annually for medium-risk users

c) Quarterly for high-risk users

3.6. Service Denial

JetUP Platform reserves the right to deny service or restrict access to users who:

a) Fail to provide required information or documentation

b) Provide false or misleading information

c) Present high AML/CFT risk profiles

4. Risk Assessment and Transaction Monitoring

4.1. Risk-Based Approach

JetUP Platform implements a risk-based approach to AML/CFT risk assessment and management, enabling efficient resource allocation and enhanced controls where risks are higher.

4.2. Risk Factors

Risk assessment encompasses:

a) Geographic Risk:

User's country of origin/residence
Jurisdiction risk ratings
International sanctions considerations

b) Client Risk:

Customer type and profile
Business sector and activities
Ownership structure (for legal entities)

c) Product Risk:

Types of services and products utilized
Transaction volumes and patterns
Delivery channel risks

d) Transaction Risk:

Transaction volume and frequency
Transaction patterns and complexity
Cross-border elements

4.3. Risk Categories

Users are classified into the following risk categories:

a) Low Risk b) Medium Risk

c) High Risk

4.4. Enhanced Due Diligence

High-risk users are subject to enhanced due diligence measures, including:

a) More frequent customer information updates

b) Additional verification of funds sources

c) Heightened transaction monitoring

d) Senior management approval for operations

4.5. Transaction Monitoring

JetUP Platform conducts continuous transaction monitoring through:

a) Automated transaction screening using predefined rules and algorithms

b) Analysis of unusual activity patterns

c) Comparison of transactions against customer risk profiles

d) Identification of transactions exceeding established thresholds

4.6. Suspicious Activity Indicators

Suspicious activity indicators include:

a) Unusually large transactions

b) Structured transactions designed to evade reporting thresholds

c) Transactions inconsistent with customer's profile

d) Frequent transfers to high-risk jurisdictions

e) Attempts to circumvent reporting thresholds

4.7. Suspicious Activity Investigation

Upon detection of suspicious activity:

a) Thorough analysis of transactions and customer profile is conducted

b) Additional information may be requested from the customer

c) Determination is made regarding suspicious activity reporting to authorities

4.8. Record Keeping

JetUP Platform maintains detailed records of:

a) All risk assessments conducted

b) Monitoring results and investigations

c) Supporting documentation

Records are retained for a minimum of 5 years and are available to authorized authorities upon request.

5. Staff Training and Internal Control

5.1. Training Program

JetUP Platform implements a comprehensive AML/CFT training program for all employees. The program aims to ensure staff understanding of their AML/CFT responsibilities and develop suspicious activity detection skills.

5.2. Training Content

The training program encompasses:

a) AML/CFT Legislative Framework:

Applicable laws and regulations
International standards and requirements
Regulatory updates and developments

b) JetUP Platform AML/CFT Policies and Procedures:

Internal control systems
Reporting requirements
Documentation standards

c) Customer Due Diligence:

KYC procedures
Customer risk assessment
Enhanced due diligence requirements

d) Transaction Monitoring:

Red flags and suspicious activity indicators
Investigation procedures
Reporting protocols

e) Compliance Responsibilities:

Staff obligations
Consequences of non-compliance
Whistleblowing procedures

5.3. Training Frequency

Training is conducted according to the following schedule:

a) Initial Training:

Mandatory for all new employees
Completed within first month of employment

b) Regular Training:

Annual refresher courses for all employees
Documentation of completion required

c) Supplementary Training:

Provided upon significant regulatory changes
Additional training for specialized roles

5.4. AML/CFT Compliance Officer

The appointed AML/CFT Compliance Officer shall:

a) Oversee overall AML/CFT policy compliance

b) Ensure timely policy and procedure updates

c) Coordinate staff training programs

d) Serve as liaison with regulatory authorities

e) Report directly to senior management

f) Maintain independence in compliance functions

5.5. Internal Audit

Regular internal audits of the AML/CFT system include:

a) Compliance Assessment:

Review of policy implementation
Evaluation of control effectiveness
Testing of monitoring systems

b) Documentation Review:

KYC records completeness
Transaction monitoring logs
Training records

c) Process Evaluation:

Customer due diligence procedures
Risk assessment methodologies
Reporting mechanisms

5.6. Reporting Requirements

Internal audit findings and AML/CFT system effectiveness are:

a) Documented in formal reports

b) Presented to senior management

c) Reviewed by the board of directors

d) Used to improve existing controls

5.7. Disciplinary Measures

Non-compliance with AML/CFT requirements may result in:

a) Disciplinary action up to termination

b) Regulatory reporting where required

c) Legal action in cases of serious violations

5.8. Confidentiality Requirements

All employees must maintain confidentiality regarding:

a) Suspicious activity reports

b) Investigation details

c) Customer due diligence information

d) Regulatory communications

6. Data Retention, Policy Review, and Final Provisions

6.1. Data Retention

6.1.1. Record Keeping Requirements

JetUP Platform maintains records of:

a) Customer identification and verification data

b) Transaction records

c) Risk assessment results

d) Suspicious activity reports

e) Internal audit findings

f) Training records

6.1.2. Retention Period

Records shall be maintained for a minimum of five (5) years from the later of:

a) Business relationship termination

b) Transaction completion

c) Investigation closure

6.1.3. Data Security

All records shall be:

a) Stored in secure electronic format

b) Protected against unauthorized access

c) Readily available to authorized personnel

d) Compliant with data protection laws

6.2. Policy Review

6.2.1. Review Schedule

This AML/CFT Policy shall be reviewed:

a) Annually at minimum

b) Upon significant legislative changes

c) Following identification of control deficiencies

d) As recommended by regulatory authorities

6.2.2. Review Responsibility

The AML/CFT Compliance Officer shall:

a) Initiate policy reviews

b) Coordinate revision processes

c) Document review outcomes

6.2.3. Approval Process

All policy amendments require:

a) Senior management review

b) Board of directors approval

c) Documentation of changes

d) Staff notification and training

6.3. Regulatory Cooperation

6.3.1. Platform Obligations

JetUP Platform commits to:

a) Prompt response to regulatory inquiries

b) Full cooperation with investigations

c) Timely implementation of regulatory directives

6.4. Conflicts of Interest

6.4.1. Staff Obligations

All Platform staff must:

a) Avoid AML/CFT-related conflicts of interest

b) Report potential conflicts immediately

c) Recuse themselves when necessary

6.5. Policy Violation Consequences

6.5.1. Enforcement

Violations may result in:

a) Disciplinary action

b) Employment termination

c) Civil or criminal liability under Georgian law

6.6. Final Provisions

6.6.1. Policy Effect

This Policy:

a) Takes effect upon senior management approval

b) Supersedes prior AML/CFT policies

c) Binds all Platform staff and users

6.6.2. Staff Acknowledgment