AML/KYC Policy

 

Introduction

 

As perakendecilik mağazacılık satış ticaret anonim şirketi has put in place an Anti-Money Laundering / Counter-Terrorist Financing Policy and a Know Your Customer Policy (collectively, the “AML Policies”). The Policies are revisited periodically and amended from time to time based on prevailing industry standards and international regulations designed to facilitate the prevention of illicit activity including money laundering and terrorist financing. All senior management and employees of As perakendecilik mağazacılık satış ticaret anonim şirketi  are required to acknowledge and be familiar with the Policies. This document covers AML Policies.

 

Money Laundering Risks

 Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing is an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.

 

The risk of money laundering or terrorist financing on As perakendecilik mağazacılık satış ticaret anonim şirketi  is extremely low. As perakendecilik mağazacılık satış ticaret anonim şirketi  does not engage in any exchange transactions between currencies, whether in crypto or fiat. Clients can only purchase products.

 

AML/KYC Policies Framework 

The Policies are designed to lay down a framework to:

 • prevent As perakendecilik mağazacılık satış ticaret anonim şirketi from being used, intentionally or unintentionally, by criminal elements for money laundering or financing terrorist activities;

• enable As perakendecilik mağazacılık satış ticaret anonim şirketi  to know and understand its customers, clientele, contributors, and other contacts with which As perakendecilik mağazacılık satış ticaret anonim şirketi has any financial dealings with (collectively, “Clients”) and their financial background and source of funds better, which in turn would help it to manage its risks prudently; 

• put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws, procedures and regulatory guidelines; and 

• equip employees and contractors of As perakendecilik mağazacılık satış ticaret anonim şirketi  with the necessary training and measures to deal with matters concerning KYC/AML procedures and reporting obligations. Our Policies will be reviewed and updated on a regular basis to ensure appropriate procedures and internal controls are in place to account for both changes in regulations and changes in our business.

 

Risk-Based Approach

 

As perakendecilik mağazacılık satış ticaret anonim şirketi  adopts and maintains a Risk-Based Approach (“RBA”) towards assessing and containing the money laundering and terrorist financing risks arising from any transactions it has with Clients. The guidelines are as follows: 

• For the purpose of risk categorization of the Clients, the relevant information shall be obtained from the Clients at or before the time of entering into a transaction;

• The outcome of the risk categorization process shall be decided based on the relevant information provided by the Clients at the time of commencement of business relationship; 

• As perakendecilik mağazacılık satış ticaret anonim şirketi  must be able to satisfy the competent authorities that due diligence was observed based on the risk profile of the As perakendecilik mağazacılık satış ticaret anonim şirketi  in compliance with the relevant legislations in place.

 

Customer Identification 

The Customer Identification Program is to be carried out: 

• before any financial transaction can be made; and 

• when there is any doubt about the authenticity, veracity, or adequacy of the previously obtained Clients’ identification data

 

Monitoring and Reporting 

As perakendecilik mağazacılık satış ticaret anonim şirketi   diligently monitors transactions for suspicious activity. Transactions that are unusual are carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary. 

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and As perakendecilik mağazacılık satış ticaret anonim şirketi   may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction. 

 

Record-keeping 

Our AML Compliance Officer is responsible for ensuring that AML records are maintained properly. 2019 © As perakendecilik mağazacılık satış ticaret anonim şirketi   8 of 9 We document our verification, including all identifying information provided by a Client, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. 

We keep records containing a description of any document that we relied on to verify a Client’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. 

With respect to non-documentary verification, we retain documents that describe the methods and the results of any measures we took to verify the identity of a Client. We also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. 

We retain records of all identification information for seven years after the account has been closed, or as long as reasonably necessary to comply with applicable regulations; we retain records made about verification of the customer's identity for seven years after the record is made, or as long as reasonably necessary to comply with applicable regulations.