Last updated: 28th June 2023

NN&O corporation LLC is incorporated in St. Vincent and Grenadines with the company number 3126 LLC 2023, registered office at Suite 305, Griffith Corporate Center, Beachmont, Kingstown, St. Vincent and Grenadines (“Company”) aims to detect, manage and mitigate the risks associated with Money Laundering and the Financing of Terrorism (“ML/FT”). The Company does this to comply with corresponding laws and regulations of Saint Vincent and the Grenadines (“SVG”), protect its reputation and uphold international standards of corporate responsibility.

Company’s current and future obligations under the:

Saint Vincent and the Grenadines Proceeds of Crime Act 2013, Anti-Money Laundering and Terrorism Financing Regulations 2014, Anti-Terrorist Financing and Proliferation Act 2015, Anti Money Laundering and Terrorist Financing Code 2017, United Nations (Anti-Terrorism Measures) Act, Cap 183 of the Revised Laws of 2009, Prevention of Money Laundering Guidance Notes and other relevant SVG laws and regulations, so far as they are known at present (collectively the “AML/CFT Regulations”).

1. General provisions

These Policy procedures for prevention of money laundering and terrorist financing, and compliance with international sanctions lay down requirements for screening the Clients in order to prevent entering into deals involving suspected money laundering and terrorist financing, and to ensure identification and reporting of such in case of existence of a risk determined by the Company. These AML/KYC Policy shall be applied in case of any issue related with money or financial transaction(s) is occurred.

The rules are primarily based on the regulations of AML/KYC legislation applicable and international sanctions acts.

2. Application of due diligence measures

The Company shall determine and take due diligence measures using results of conducted international risk assessment and provisions of national risk assessment.

Depending on the level of the risk of the Client and depending on the fact whether the business relationship is an existing one or it is about to be established, the Company shall apply either normal KYC/AML measures, simplified KYC/AML measures or enhanced KYC/AML measures. The Company may also apply continuous KYC/AML measures to ensure ongoing monitoring of business relationships.

KYC/AML measures may include, but are not limited with, the following procedures:
• Identifying the Client and verifying its identity using reliable, independent sources, documents or data, including e-identifying;
• Assessing and, as appropriate, obtaining information on the purpose of the business relationship;
• Conducting ongoing KYC/AML on the Client's business to ensure the Company’s knowledge of the Client and its source of funds is correct;
• Obtaining information whether the Client is a PEP or PEP’s family member or PEP’s close associate;
• Obtaining information from any third party, e.g. government authorities.

The Company may establish the source of wealth of the Client, where appropriate.

To comply with the KYC/AML obligation, the Company or any third party appointed by the Company shall have the right and obligation to:
• request appropriate identity documents to identify the Client;
• request documents and information regarding the activities of the Client and legal origin of funds;
• screen the risk profile of the Client, select the appropriate KYC/AML measures, assess the risk whether the Client is or may become involved in money laundering or terrorist financing;
• re-identify the Client, if there are any doubts regarding the correctness of the information received in the course of initial identification.

The objective of the continuously applied KYC/AML measures is to ensure on-going monitoring of Clients. Conducting ongoing monitoring of the Business Relationship includes:
• Keeping up-to-date the documents, data or information, obtained during taking KYC/AML measures;
• Paying particular attention to Client’s actions, leading to criminal activity or money laundering or terrorist financing;
• Paying particular attention to Client’s actions, leading to criminal activity or money laundering or terrorist financing.

The Company evaluates the substance and the purpose of the Client’s activities, in order to establish the possible links with money laundering or terrorist financing. The evaluation should result in an understanding of the purpose of the business relationship for the Client, the nature of the Client’s business, the risk levels of the Client and, if necessary, the sources of funds.

3. Identification of a person

Identification of a client is coming to know a client's identifying details, such as their name and address, his financial status and the capacity in which he is entering into the business relationship with the Company.

Verification is obtaining evidence satisfactory to the Company which supports this claim of identity.

The Company will:
• Collect certain identification information from each client;
• Utilize risk based measures to verify the identity of each client;
• Record client identification information and the verification methods and results.

For individual clients the Company will collect the following CDD information:
a) Client's full name;
b) Client's date of birth;
c) Passport number/identification card number;
d) Country of residence/location of client;
e) Address;
f) Mobile telephone number and e-mail.

For corporate clients the Company will collect the following CDD information:
a) Full company name;
b) Registration number and date;
c) Country of registration;
d) Registered address;
e) Mobile telephone number and e-mail;
f) Information on the representative of the company (indicating the document of appointment).

The list of documents and information is not exhaustive. The Company may require additional documents at its discretion.

4. Risk assessment and action steps

The Company applies the following risk categories:
• Low risk;
• Medium Risk;
• High risk.

The Company is entitled to apply any combination of AML/KYC procedures based on a risk category of a Client and on a risk-based approach to each Client of the Company.

In accordance with the applicable laws and the requirements of international organizations, the Company may, where appropriate and without the obligation of obtaining the Client’s approval or notifying the Client, notify regulating and/or law enforcement agencies of any suspicious transactions.

The Company shall periodically refer to and consult the lists published by the local authorities and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to the OFAC, UN and other sanctions lists, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company’s Client, and/or such Client’s country of jurisdiction is included in the above lists.

5. Client’s covenants

The Client hereby certifies that they have read and understood this Policy, and the Client shall operate in full compliance with the requirements and standards outlined in the Policy and comply with all applicable laws and other regulations and requirements governing its activities as a Client of the Company.

The Client acknowledges that they are responsible for their actions in accordance with the effective laws in the field discussed in this Policy and shall bear responsibility pertaining to failure to comply with such laws.