Bfunded Evaluation OÜ is dedicated to upholding the highest standards of compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. The company’s AML and Terrorist Financing Policy aims to actively mitigate the risks associated with these issues. In alignment with legal requirements, Bfunded Evaluation OÜ obtains, verifies, and records information to identify each person opening an account, supporting the government’s efforts to combat terrorism financing and money laundering activities. The company is also obligated to report any suspicious client activity related to money laundering.

1. Definition of Money Laundering:

Money laundering refers to the process of disguising the origins of funds obtained through illegal activities (e.g., fraud, corruption, or terrorism) by converting them into seemingly legitimate assets. This process typically involves three stages:

2. Placement:

Illegal funds are introduced into the financial system through instruments such as bank deposits, money transfers, or high-value goods purchases. To evade detection, smaller deposits may be made instead of a single large deposit, a tactic known as smurfing.

3. Layering:

Funds are moved through various accounts and financial instruments to obscure their origin, complicating efforts to trace the transactions.

4. Integration:

Laundered funds are reintroduced into the legitimate economy, often through the purchase of goods and services.

Bfunded Evaluation OÜ strictly adheres to AML principles and actively works to prevent the use of its services for laundering funds, financing terrorism, or other illicit activities. As part of this commitment, the company neither accepts nor disburses cash under any circumstances. Additionally, Bfunded Evaluation OÜ reserves the right to suspend or terminate any client operations suspected of illegal activity or potential money laundering.

Company Procedures

To ensure compliance with AML and KYC regulations, Bfunded Evaluation OÜ implements the following measures:

1. Know Your Customer (KYC) Policy and Due Diligence:

Every client undergoes a thorough verification process before any cooperation begins. The company ensures that sufficient evidence is provided to confirm the identity of each customer or counterparty. Enhanced scrutiny is applied to clients from countries with inadequate AML standards or those deemed high-risk for crime and corruption.

2. Individual Clients:

During registration, clients provide personal information such as full name, date of birth, country of origin, and residential address. Verification requires submission of:

• A valid passport (with clear visibility of the photo and signature), driver’s license, or national ID card.
• Proof of permanent address (e.g., utility bills or bank statements), issued within the last three months.

3. Corporate Clients:

For corporate applicants, the following documentation is required:

• Certificate of Incorporation or equivalent.
• Memorandum and Articles of Association.
• Proof of registered company address (e.g., Certificate of Good Standing).
• Board resolution authorizing account opening and specifying authorized signatories.
• Proof of identity for directors, beneficial owners, or authorized representatives, in line with individual client verification requirements.

4. Monitoring Client Activity:

Client activities are monitored to identify suspicious transactions that deviate from their legitimate business or transaction history. Bfunded Evaluation OÜ employs both automated and manual systems to detect and prevent potentially illegal activity.

5. Record Keeping:

The company retains transaction records, identification documents, and AML-related files for at least seven years after an account is closed.

Measures Against Suspicious Activities

In the event of suspected money laundering or other criminal activities, Bfunded Evaluation OÜ will:

• Report suspicious activity to the relevant regulatory authority in accordance with applicable laws.
• Temporarily block the client’s account or terminate the relationship at its discretion.
• Take necessary actions to prevent the execution of suspicious transactions.

Bfunded Evaluation OÜ maintains full authority to act decisively in these matters to uphold compliance with AML and CTF regulations.

This policy reflects the company’s unwavering commitment to ethical practices and adherence to legal requirements in all operations.