The purposes of the UAB Novum Digital (hereinafter in the text Company or Novum Digital) Anti-Money Laundering, Counter-Terrorist Financing and Know Your Client Policy (hereinafter — the “AML/CTF and KYC Policy”) is to identify, prevent and mitigate possible risks of Novum Digital being involved in illegal activity.

To confirm with international and local regulations, Novum Digital has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users.

Anti-money laundering (AML) refers to the laws, regulations and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

Combating the Financing of Terrorism (CFT) is a set of government laws, regulations, and other practices that are intended to restrict access to funding and financial services for those whom the government designates as terrorists. By tracking down the source of the funds that support terrorist activities, law enforcement may be able to prevent some of those activities from occurring.

All firms must adhere to the Money Laundering, Terrorist Financing and the recommendations from the Financial Action Task Force (FATF), an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.

To help fight the funding of terrorism and money laundering activities, the Law requires all financial institutions to obtain, verify and record information that identifies each person or entity that opens an Account. We are required by law to ask you to provide your name, address, date of birth, and other information about you, your organization, or persons related to your organization that will allow us to identify you before we approve your Account. We also may ask you to provide certain identifying documents, such as your driver’s license or passport or your organization’s articles of incorporation, and may obtain credit and other consumer reports to assist us in verifying your identity and in determining whether you satisfy our account criteria. Unless you provide the requested information and documentation, we may not be able to open your Account.

By applying for a Novum Digital Account, you agree to provide the information and documentation requested by Novum Digital and consent to Novum Digital’s acquisition of credit and other consumer reports about you for the purposes described above.

The Novum Digital User due diligence (“CDD”) procedure requires the Users to provide Novum Digital with reliable, independent source documents to identify them and confirm their residential address. Such documents may include, for example, a national ID card, an international passport, a bank statement, a utility bill. For such purposes, Novum Digital reserves the right to collect the Users’ identification information for the purposes of compliance with its AML/CFT and KYC Policy. Novum Digital will take steps to confirm the authenticity of documents and information provided by Users. Novum Digital will also look to verify identification information through secondary sources and reserves the right to investigate further the cases of Users where Novum Digital is not satisfied with the documentation submitted.

Novum Digital Users must complete the Novum Digital identity verification process (who you are) before trading. After verification is completed the User consents to transaction Monitoring, Novum Digital analyses User’s transactional patterns (what they do). Novum Digital relies on data analysis as a risk assessment and suspicious activity detection tool. These tools perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. In connection with the AML/CFT and KYC Policy, Novum Digital will:

• monitor all transactions. Novum Digital reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement.
• request the User to provide any additional information and documents in case of suspicious transactions.
• suspend or terminate work with a client if there is reasonable suspicion that such a client is engaged in illegal activities.

However, the above list is not exhaustive and the Compliance Person will monitor Users’ transactions on a regular basis in order to define whether such transactions are to be reported and treated as suspicious.

The European Union adopted robust legislation to fight against money laundering and terrorist financing which contributes to those international efforts. The Commission ensures the effective application of this legislation by reviewing the transposition of EU acquis and working with networks of competent authorities.

Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) constantly assesses compliance with the principal international standards to counter money laundering and the financing of terrorism and the effectiveness of their implementation, and make recommendations to national authorities in respect of necessary improvements to their systems, also conducts thematic typologies research of money laundering and terrorist financing.

FATF continuously monitors the new or developing methods that criminals use to launder the proceeds of their crimes, and how terrorists raise, use and move the funds they need. FATF typologies reports aim to raise awareness with authorities as well as the private sector about the risk of particular sectors or products, so that they can take appropriate actions to mitigate these risks.
In order to meet its obligations regarding Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) Novum Digital completes an annual AML Risk Assessment. The aim of the AML Risk Assessment is to prevent criminals using Novum Digital to launder money by highlighting risks and assessing controls Novum Digital has put in place. A risk-based approach is taken to identify Users and monitor how they use our Services.

The Compliance Person is responsible for managing financial crime risks and making improvements in financial crime risk management through identifying the general and specific money laundering risks that Novum Digital is facing, determining how these risks are mitigated by the Novum Digital AML controls and establishing the residual risk that remains for Novum Digital.

Risk Users:

Suspicious facts such as but not limited to: discrepancies in provided id documents, fictitious person, stolen identity, counterfeited id document, post box home address, previous financial crime record, terrorist record, wanted person, no contact phone number, not valid documents, discrepancies in provided documents for the legal person, etc.
Politically exposed persons such as but not limited to the: prominent public functions: head of state, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a state-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials.

Risk By Countries:

EU policy on high-risk third countries based on Directive (EU) 2015/849, Article 9, the Commission is mandated to identify high-risk third countries having strategic deficiencies in their regime on anti-money laundering and countering the financing of terrorism. The aim is to protect the integrity of the EU financial system.

5th Anti-Money Laundering Directive ((EU) 2018/843) imposes stricter due diligence requirements for business relationships or transactions that involve high-risk third countries. These include requirements to obtain additional information on the customer and beneficial owner, sources of funds and wealth, reasons for the transaction, and a requirement to obtain senior management approval to establish or continue the relationship. The Directive also contemplates that Member States may impose additional restrictions on conducting business relationships.