Compliance control
The key objective of the compliance service is to create a high compliance culture and standards of ethical business norms, as well as an effective regulatory risk management system which is a part of the overall internal control system of the Company. The system is aimed at ensuring strict compliance with the requirements of the applicable legislation, including the Acts of the Astana International Financial Center (hereinafter referred to as the AIFC), internal policies and documents of the Company, in order to minimize possible regulatory and reputational risks in the Company's activities, ensure continuity of the Company's activities in the long term and maintain trust of the Company’s clients, counterparties and the general public as a whole.
For these purposes, the Company has created units that ensure implementation of the compliance control system, and also provides for the Compliance Officer, with independent and autonomous statuses.
In its activities, the Company strives to comply with the best local and international practices in the field of compliance, including in the field of anti-money laundering.
AML/CFT
Anti-Money Laundering and Counter-Terrorist Financing
The Company being a financial organization registered at the AIFC, in accordance with the requirements of the legislation is a subject of financial monitoring and, in carrying out its activities, ensures compliance with the requirements of the legislation of the Republic of Kazakhstan and the AIFC on anti-money laundering and counter-terrorist financing (hereinafter referred to as the AML/CFT).
The Company has developed and implemented internal documents regulating the procedure for managing the risk of ML/FT and implementing internal control for the AML/CFT purposes:
AML/CFT Policy
Sanctions compliance
In the context of global sanctions restrictions, the Company pays special attention to issues of sanctions compliance and observance of applicable sanctions regimes to maintain a high level of trust of clients, counterparties, partners, regulatory authorities, and to ensure protection of the infrastructure used from possible sanctions risks. For this purpose, the Company has implemented a comprehensive risk assessment taking into account the specifics of sanctions regimes, certain transactions and client/counterparty profiles.
Key sanctions compliance measures include the following:
Sanctions List Monitoring:
The Company regularly monitors current sanctions lists of UN Security Council resolutions, OFAC (USA), EU, and UK, to prevent cooperation with individuals or organizations subject to the sanctions.
Client and counterparty verification:
The Company carries out a comprehensive verification of all clients and partners, including identification of ultimate beneficiaries, for compliance with sanctions requirements. This allows identifying and preventing potential risks at the initial stage of cooperation.
Risk assessment and management:
The Company has developed internal policies and procedures to identify high-risk clients and transactions and has implemented measures to limit or terminate cooperation, when necessary to comply with sanctions regimes.
Regular employee training:
The Company's employees receive training on current sanctions issues, including identifying so-called red flags, to ensure compliance with the sanctions regulations at all levels of the Company.
Implementation of modern technologies to automate compliance processes:
The Company uses advanced solutions for automatic monitoring of the client base and operations, that allows it to quickly respond to changes in the sanctions lists and reduce the likelihood of violations.
The Company understands importance of compliance with the international sanctions regimes and takes all necessary measures to prevent and suppress any attempts to evade sanctions. We believe that sanctions compliance is not only compliance with laws, but also a responsibility to the international financial community. We are committed to transparency in our business operations and are confident that our sanctions compliance policy contributes to the long-term development of the Company and strengthening trust in us.
Control of fraud and corruption
The Company has developed measures and implemented control procedures to prevent and combat fraud and corruption, and has organized anti-corruption training for employees.
The Company adheres to a zero-tolerance policy towards fraud and corruption in any form and is guided by the following principles in its activities:
- legality
- transparency
- ethics
- respect for the rights and legitimate interests of partners, employees and clients, protecting them from fraudulent and corrupt practices;
- avoidance of conflicts of interest.
If you become aware of any cases of corruption or a fraudulent activity, abuse of official position, or violation of ethics, please send a message to the following email address: [email protected]
Insider trading and market manipulation
The Company establishes and maintains systems and controls that ensure, as far as reasonably practicable, that the Company and its employees do not commit or assist others in committing acts that may constitute market abuse, including misuse and dissemination of inside information, market manipulation.
In accordance with the applicable legislation, the Company notifies the competent authority about any suspicions of the market abuse.
The Company takes all reasonable steps to protect insider information from the misuse and to prevent the possibility of market manipulation, including:
- controls and restricts access to the Company's insider information
- uses software tools to identify accounts of the Company's employees
- monitors the Company's clients' transactions for market manipulation
Conflict of interest
A conflict of interest is a situation in which the interests of the Company, its officials, employees and clients do not coincide with each other and/or a situation in which the personal interest of an official or an employee of the Company influences or may influence the conscientious and impartial performance of official duties.
The Company uses the following methods to resolve conflicts of interest:
- priority of the client's interests over the interests of the Company, when providing services
- change or refusal of a transaction/service/product that leads to the emergence or implementation of a conflict of interest
- disclosure of a conflict of interest that has not been excluded
Data Protection Office
DPO (Data Protection Office) is a unit of the Company responsible for protecting the personal data of clients, in accordance with the requirements of the following:
- Law No. 94-V of the Republic of Kazakhstan, On Personal Data Protection, dated May 21, 2013
- Astana International Financial Centre (AIFC)
For questions regarding the protection and processing of personal data, please contact us at [email protected]
For financial institutions and counterparties
FATCA
CRS
FATCA
On September 11, 2017, the Government of the Republic of Kazakhstan and the Government of the United States of America signed the Agreement on Improvement of International Tax Discipline, which entered into force on April 5, 2022. Within the framework of the US Foreign Account Tax Compliance Act (hereinafter referred to as the FATCA), the Company registered on the website of the US Internal Revenue Service (IRS):
Classification according to the FATCA - Reporting Model 1 FFI
GIIN — FDW83C.99999.SL.398