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AML Policy and KYC
“Know Your Client” Requirements

Atrium attaches the utmost importance to the struggle against money laundering and the financing of terrorism both inside the company as well as in the framework of the projects that it accompanies.

Atrium is committed to carrying out its business objectively, honestly and impartially, ensuring the primacy of the interest of the company, its clients and market integrity. This commitment to respect the highest standards of ethical and professional conduct is not only in order to assure the compliance with laws and prevailing rules in the different jurisdictions in which Atrium intervenes, but also to win and safeguard the confidence of its clients, shareholders, collaborators and partners over the long term.

Money laundering / Financing of terrorism

On account of the nature of the activities of Atrium, money laundering and financing of terrorism pose specific and significant risks from a judicial point of view and for the protection of its reputation. Compliance with laws and regulations in the struggle against money laundering, which exist in the countries where Atrium carries out its business, is of the utmost importance. As a result Atrium has developed a program, which includes the following:

– Appropriate internal procedures and controls (measures of monitoring)
– A training plan when staff is recruited and which will be regularly updated

Monitoring measures

Good knowledge of the client (KYC – Know Your Client) implicates mandatory identification and verification of the identity of the client including, as the case may be, the powers of those acting for the client, in order to secure the certitude of dealing with a legitimate and legal client.

– When it applies to a physical person: by the presentation of an official document which is currently being validated and bears a photograph. The details to be recorded and saved are the surname(s) – including the maiden name for married women, first names, date and place of birth of the person (nationality), as well as the nature, the date, place of issue and validity of the document, the name and the designating authority or the person who issued the document and as the case may be, the name of the person who authenticated it;

– When it applies to a legal entity, by the notification of the original or a copy of any acts or extract from official registers not more than three months old, its legal form, Head Office address and identity of its partners and social partners

Furthermore, the following information is required:

Complete address
Telephone numbers and/or GSM
Email(s)
Profession(s)

As well as the following documents:

Certified copy of passport
Curriculum vitae
Bank statement (s)
Bank reference letter
If necessary, further documents of identity (identity card, driving license, residence permit.

This is not a comprehensive list and other information may be taken into account according to the circumstances.

Atrium expects its clients to provide correct and up-to-date information, and it is mandatory for the client to inform it as soon as possible of any modifications, which could arise.

Action in cases, where fraud is suspected:

In case of any suspicion of money laundering or financing of terrorism, or even any doubt regarding the truthfulness or the relevance of the documents obtained to prove identity, Atrium is committed to:

Not engage in any business relations or carry out any transactions;
End any business relations, without giving any necessary explanation.

To comply with current international anti-money laundering and client due diligence (CDD) regulations, all clients and their authorized representatives must present:

– Passport copy of (ultimate) beneficial owner and of any Attorney or other representative nominated by the beneficial owner.
– Confirmation of residential address of beneficial owner and or Attorney (representative) in the form of a utility bill, bank or credit card statement not older than 3 months, showing individual\’s name and residential address.
– Description of proposed business activity of the new company, including geographical areas of operation and approximate turnover.
– Curriculum vitae
– Bank reference

If a body corporate entity is part of the company structure (corporate shareholder or corporate director), additional related documents may be required to verify the ultimate beneficial owners of final entity.

Please note that Atrium & Associates Ltd reserves the right to request additional information for compliance purposes and in such cases, detailed instructions will be provided by an Atrium Account Manager. All data provided by clients is strictly confidential.

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