Anti-Money Laundering (AML) Policy

1. Purpose of the Policy

Brolexy UAB Anti-Money Laundering (AML) Policy aims to prevent and detect money laundering and terrorist financing activities. This policy aligns with international and national AML regulations to ensure that all business activities adhere to legal standards for identifying and reporting suspicious activities.

2. Scope

This policy applies to all employees, directors, officers, and contractors of Brolexy UAB. It covers all products and services provided by the company and applies to all geographical regions where Brolexy UAB operates.

3. Customer Due Diligence (CDD)

Identification: Brolexy UAB requires all customers to provide verifiable identification documents (such as passport, and national ID) to establish their identity before any business relationship begins.

Risk Assessment: Customers are classified as low, medium, or high-risk based on various factors such as location, transaction type, and industry.

Enhanced Due Diligence (EDD): For high-risk clients, additional information is required, including the purpose of the relationship, source of funds, and monitoring of transactions.

4. Transaction Monitoring

All transactions are continuously monitored to detect unusual or suspicious activity patterns. Brolexy UAB uses automated tools to flag irregular transactions, which are then reviewed by the compliance team.

5. Reporting and Record-Keeping

Brolexy UAB AML compliance officer is responsible for filing Suspicious Activity Reports (SARs) to relevant authorities when suspicious transactions are detected.

Records of customer identification, transaction details, and SARs are maintained for at least five years after the business relationship ends.

6. Training

Regular AML training is provided to all employees to ensure awareness of AML policies, procedures, and the importance of identifying and reporting suspicious activities.

7. Internal Controls and Audits

Brolexy UAB conducts periodic audits of its AML controls and procedures to ensure their effectiveness and compliance with current regulations.

Internal controls include access to confidential customer information, verification of transaction legitimacy, and adherence to due diligence standards.

8. Compliance Officer

Brolexy UAB has appointed an AML compliance officer responsible for overseeing the implementation of the AML policy, training staff, filing SARs, and coordinating with regulatory bodies.

9. Policy Review

The AML policy is reviewed annually and updated as necessary to reflect changes in regulations, business operations, or risk profile.