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ComiBlock Capital LLC and its subsidiary are committed to full compliance with all applicable laws and regulations regarding anti-money laundering procedures. ComiBlock Capital LLC and its subsidiary have adopted and will enforce the provisions outlined in Anti-Money Laundering Regulations, 2017 (‘AML Regulations’) to prevent and detect money laundering, terrorist financing, and other illegal activities.
ComiBlock Capital LLC and its subsidiary, its personnel, and/or premises are inadvertently used for money laundering or other illegal activities, ComiBlock Capital LLC and its subsidiary can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee (each, an “employee”) is familiar with and complies with the policies and procedures set forth in this Compliance Manual.
This Compliance Statement is designed to assist all clients in adhering to ComiBlock Capital LLC and its subsidiary's policy and procedures, which, if followed diligently, are designed to protect themselves, ComiBlock ComiBlock Capital LLC and its subsidiary, its employees, its facilities, and its activities from money laundering or other illegal activities.
To ensure that ComiBlock Capital LLC and its subsidiary policies and procedures are adhered to, ComiBlock Capital LLC and its subsidiary shall designate an Anti-Money Laundering Compliance Officer (the “Compliance Officer”).
The Compliance Officer is responsible for establishing and conducting employee training programs to ensure that all appropriate employees are aware of the applicable Anti-Money Laundering Regulations, ComiBlock Capital LLC, and its subsidiary's Anti-Money Laundering Policies & Procedures and their responsibilities with respect to these policies.
Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activity are transformed into funds with an apparently legal source.
Money laundering has many destructive consequences, both for society as a whole and for those entities involved in money laundering activities. With respect to society as a whole, money laundering may provide resources for drug dealers, terrorists, and other criminals to operate and expand their criminal activities.
With respect to entities, any involvement, whether to instigate, assist, conceal, or ignore the source, nature, location, ownership, or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved. Additionally, the adverse effects, including the adverse publicity to the Firm, associated with involvement in money laundering events cannot be emphasized enough.
Money laundering can involve the proceeds of drug dealings, terrorist activities, arms dealings, mail fraud, bank fraud, wire fraud, or securities fraud, among other activities
Internal controls and policies should be established and recorded in order to:
Note: The obligation to report does not depend on the amount involved or the seriousness of the offense. There are no de-minimis concessions.
Any employee shall immediately notify the Compliance Officer if he/she suspects or has any reason to suspect that any potentially suspicious activity has occurred or will occur if a transaction is completed. Employees are encouraged to seek the assistance of the Compliance Officer with any questions or concerns they may have with respect to ComiBlock Capital LLC and its subsidiary's Anti-Money Laundering Policies or Procedures.
Responsibilities of the Compliance Officer include the following:
As part of the ComiBlock Capital LLC and its subsidiary's anti-money laundering program, all employees are expected to be fully aware of the ComiBlock Capital LLC and its subsidiary's anti-money laundering policies and procedures.
Each employee is required to read and comply with this Compliance Manual, address concerns to the Compliance Officer and sign the acknowledgement form confirming that he/she has read and understands ComiBlock Capital LLC and its subsidiary's anti-money laundering policies and procedures.
To ensure the continued adherence to ComiBlock Capital LLC and its subsidiary's anti-money laundering policies and procedures, all employees are required to reconfirm their awareness of the contents of this Compliance Manual by signing the acknowledgement form annually, or more frequently, as required by the Compliance Officer.
All employees are required;
ComiBlock Capital LLC and its subsidiary's anti-money laundering policies and procedures are intended to ensure that, prior to accepting funds from Clients, all reasonable and practical measures are taken to confirm the Clients’ identities.
And to verify that any third party upon whom the ComiBlock Capital LLC and its subsidiary rely for client identification, such as a KYC technology providers and other financial intermediaries, or any other third-party adheres to the same standards.
These Client Identification Procedures are based on the premise that the ComiBlock Capital LLC and its subsidiary will accept funds from a new and existing client only after:
The Client Identification Procedures should be reviewed in light of the specific characteristics presented by a client and in any instance, the Compliance Officer may determine to apply Enhanced measures for reasons other than those discussed in “High-Risk Clients”.
As a reference tool, an Individual Client KYC Checklist is used. Employees are encouraged to provide the Compliance Officer with any revisions they consider appropriate.
The Compliance Officer shall retain copies of all documents reviewed or checklists completed in connection with its Client Identification Procedures in accordance with ComiBlock Capital LLC and its subsidiary’s Client Records Retention policies.
CLIENT IDENTIFICATION PROCEDURES FOR NATURAL PERSONS
ComiBlock Capital LLC and its subsidiary shall take reasonable steps to ascertain satisfactory evidence of an individual Client’s name, address, date, and place of birth, including the employer’s address and the source of the Client’s funds.
In order to confirm the identity of the Client, copies of certain of the following documents will be obtained and retained for ComiBlock Capital LLC and its subsidiary's records:
The Compliance Officer will provide and will continuously update a list of the types of Clients that ComiBlock Capital LLC and its subsidiary record considers to be of ‘high risk,’ such that enhanced due diligence procedures are warranted compared to the routine Client Identification Procedures.
Following are the examples of Clients who pose a high money laundering risk:
Non-Cooperative Jurisdiction means any foreign country that has been designated as non-cooperative with international anti-money laundering principles or procedures by an intergovernmental group or organization, such as the Financial Action Task Force on Money Laundering (“FATF”).
ENHANCED CLIENT IDENTIFICATION PROCEDURES FOR ‘HIGH-RISK’ NATURAL PERSONS
Enhanced Client Identification Procedures for ‘high risk’ natural persons as Clients include, but are not limited to, the following:
The enhanced due diligence procedures undertaken with respect to ‘high risk’ Clients must be thoroughly documented in writing, and any questions or concerns with regard to a ‘high risk’ Client should be directed to the Compliance Officer.
DE-MINIMIS CONCESSIONS: The obligation to report does not depend on the amount involved or the seriousness of the offense. There are no de-minimis concessions.
Copies of all documents related to ComiBlock Capital LLC and its subsidiary's client Identification procedures will be retained for an appropriate period of time and, at a minimum, the period of time required by applicable law or regulation.
The documents ComiBlock Capital LLC and its subsidiary retains are copies of documents reviewed in connection with Client Identification Procedures or enhanced due diligence procedures, Client identification checklists if any, or similar due diligence documentation, and any other documents required to be retained by applicable anti-money laundering legislation.
ComiBlock Capital LLC and its subsidiary will retain client records for so long as a client remains active and for a minimum of five years after this relationship ends.
The Compliance Officer shall coordinate a periodic review of the ComiBlock Capital LLC and its subsidiary's existing Client list, and ensure the adequacy of due diligence performed on existing Clients.
In addition, ComiBlock Capital LLC and its subsidiary's policies, procedures, and controls may provide for the detection of suspicious activity, and if detected may require further review to determine whether the activity is suspicious, as described below.
For example, in some circumstances, the following activities, none of which per se constitutes suspicious activity, may be indicative of activity that may require further investigation:
ComiBlock Capital LLC and its subsidiary require any employee who detects suspicious activity or has reason to believe that suspicious activity is taking place immediately to inform his or her immediate supervisor as well as the Compliance Officer.
Under no circumstances may an employee discuss the suspicious activity, or the fact that it has been referred to the Compliance Officer, with the Client concerned (Required by Law).
The Compliance Officer shall determine in consultation with the higher management whether to report to appropriate law enforcement officials (i.e. FMU-Financial Monitoring Unit) any suspicious activity of which he becomes aware within 7 working days of knowing the suspicious activity (Required by Law).
Procedure Where Enhanced Due Diligence Is Required
Below is the procedure whereby risk assessment of client due diligence instigates the ComiBlock Capital LLC and its subsidiary to conduct Enhanced Due Diligence (EDD);
ComiBlock Capital LLC and its subsidiary shall monthly prepare a compliance status report, whereby the net traded/investment value (value bought less value sold) would be equal to or greater than the below thresholds; Investor minimum threshold is $1,000.
ComiBlock Capital LLC and its subsidiary will also maintain a summary report of the investors and merchants who fall under the above category. The summary report covers the following details;
A regular review of the program should be undertaken to ensure that it is functioning as designed. Such a review could be performed by external or internal resources and should be accompanied by a formal assessment or written report.
If and when regulations are amended concerning reporting of suspicious activities, ComiBlock Capital LLC and its subsidiary will amend this Compliance Manual to comply with those regulations.
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