Anti-Money Laundering Policy (AML Policy)
Money laundering is the cover-up of illegal resources by converting them into cash or seemingly legitimate investments.
As Petrimex International Ltd (hereinafter referred to as “Petrimex”), we attach importance to the account security of our customers and partners (hereinafter Entity). We apply our AML (Money Laundering) policy to prevent money laundering in any way. In this context, the Money Laundering Policy (hereinafter referred to as “AML Policy”) summarizes the procedures and mechanisms implemented by Petrimex to prevent money laundering.
The purpose of the Anti-Money Laundering Policy is; to evaluate the Entities, transactions, and services within Petrimex with a risk-based approach, raising awareness and obtaining information on the prevention of criminal laundering activity and financing terrorism.
Petrimex has regulated its AML Policy in accordance with international legal norms and standards and applicable legislation, implicitly verifying the identity of all Entities to a reasonable level, applying a risk-based approach to monitoring Entity transactions, and flagging any suspicious transactions carried out. It has taken many measures such as notifying the relevant institutions and organizations within the framework of current legislation and recording the transactions, ensuring the necessary organization to coordinate the execution and applicability of the AML Policy of the Company.
1. Petrimex follows the following policies :
✓ Will not work with criminals and/or terrorists;
✓ Will not process transactions resulting from criminal and/or terrorist activities;
✓ Will not facilitate any action related to crime and/or terrorist activities.
2. Risk assessment :
Petrimex adopts a risk-based approach to money laundering and financing terrorism, in line with both national and international requirements. Thus, measures to prevent money laundering and financing terrorism are proportionate to the risks identified and allow resources to be effectively allocated. Resources are used on a priority basis, and the greatest attention is paid to the highest risks.
Since Petrimex adopts a risk-based approach in monitoring the financial activities of Entities, in order to prevent money laundering and financing of terrorism, Petrimex can perform risk analysis with the following methods and select the relevant Entities to monitor within the framework of the information obtained as a result of the risk analysis.
The Entities and transactions in the high-risk group are as follows :
✓ If the total amount of a single purchase-sale transaction or multiple linked transactions is equal to or more than 50,000 USD;
✓ If the total amount of a single clearing transaction or multiple linked transactions is equal to or more than 50,000 USD;
✓ In cases requiring suspicious transaction reporting within the framework of current legislation;
✓ In case of doubt about the accuracy and adequacy of previously acquired credentials;
✓ If a third party performs complex transactions that have the potential to hide the beneficiaries;
✓ In cases where sources of funds cannot be easily verified;
✓ Unusual transactions with any economic or visible legitimate purpose;
3. Process Monitoring
Monitoring Entity transactions and analyzing the data obtained is also an essential tool for risk assessment and detection of suspicious transactions. In the case of suspicion of money laundering, Petrimex will monitor all transactions (high-risk transactions, Complex and unusual transactions, transactions with high-risk countries, etc.) and has the right to :
✓ Report suspicious transactions to the relevant law enforcement units;
✓ Request the Entity to provide additional information and documents;
✓ Suspend or close the client account;
The list above is not exhaustive. The AML Policy Compliance Officer monitors Entities’ transactions daily to determine whether or not they are suspicious.
4. Know Your Customer Policy
A separate policy implemented for KYC.
5. Verification Procedure
Petrimex will establish its own procedures to determine anti-money laundering standards and compliance with the Know Your Customer (KYC) policy.
Petrimex reserves the right to collect the credentials of Entities for the purposes of the AML policy. This information is processed in accordance with Petrimex’s Privacy Policy and stored securely.
6. Reporting
Within the scope of the services provided by Petrimex, in cases that raise suspicion about money laundering and the financing of terrorism, the AML Officer reports the case pursuant to current legislation, regardless of the amount and number of transactions determined as suspicious as a result of the investigations carried out. The real persons who carry out the suspicious transaction and their legal representatives, the managers, and personnel who do not comply with the obligation to report the suspicious transaction will be liable to various legal, administrative, and criminal sanctions.
7. Anti-Money Laundering Officer
The Anti-Money Laundering Officer who is the Petrimex employee responsible for ensuring compliance with the AML Policy has the following tasks :
✓ Collection of Entities’ identification information;
✓ Establishing and updating internal policies and procedures for creating, reviewing, submitting, and storing all necessary reports in accordance with existing laws and regulations;
✓ Monitoring and analyzing significant deviations from Entities’ ordinary activities;
✓ Implementing a records management system for recording and retrieving documents, files, forms, and log session inputs;
✓ Regularly updating risk assessments;
8. Training, Updating, and Internal Audit
Petrimex fulfills all its obligations within the scope of training with the personnel policy and procedures issued according to the current legislation. In this context, Petrimex provides training to its personnel, especially with regard to the Anti-Money Laundering Procedure, and ensures that this information is kept up-to-date.
Petrimex periodically audits whether its activities related to the “Law Against Money Laundering and Terrorism Financing” regulations and communiqués comply with the current legislation, Company policies, and procedures.