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Anti-Money Laundering (AML) Policy

Last updated: April 9, 2025

1. Introduction

Kuinji is committed to preventing money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. This Anti-Money Laundering (AML) Policy outlines the principles and procedures we follow to comply with applicable AML laws and regulations.

2. Policy Statement

Kuinji is committed to:

  • Complying with all applicable anti-money laundering laws and regulations
  • Implementing effective controls to reduce the risk of money laundering
  • Verifying the identity of our clients
  • Monitoring transactions for suspicious activity
  • Maintaining appropriate records
  • Training our employees on AML awareness and procedures
  • Reporting suspicious activities to relevant authorities where required by law

3. Risk-Based Approach

We apply a risk-based approach to our AML procedures, focusing enhanced due diligence on clients, transactions, and geographies that present a higher risk of money laundering or terrorist financing.

4. Customer Due Diligence

Before establishing a business relationship, we conduct appropriate customer due diligence, which includes:

  • Identifying and verifying the client's identity using reliable, independent source documents
  • Identifying the beneficial owner(s) and taking reasonable measures to verify their identity
  • Understanding the nature and purpose of the business relationship
  • Conducting ongoing due diligence on the business relationship

Enhanced due diligence will be applied to clients who are:

  • Politically Exposed Persons (PEPs)
  • Located in high-risk jurisdictions
  • Operating in high-risk industries
  • Exhibiting unusual or suspicious transaction patterns

5. Transaction Monitoring

We monitor client transactions on an ongoing basis to detect suspicious activity that may indicate money laundering or terrorist financing. This includes:

  • Reviewing transactions that are complex, unusually large, or have an unusual pattern
  • Monitoring transactions involving high-risk countries or jurisdictions
  • Scrutinizing transactions that do not appear to have a legitimate business purpose

6. Record Keeping

We maintain records of all client identification documents, transactions, and any reports filed with regulatory authorities for a minimum of five years or as required by applicable laws.

7. Employee Training

All employees receive regular training on:

  • AML laws and regulations
  • Identification of money laundering risks
  • Customer due diligence procedures
  • Record keeping requirements
  • Procedures for reporting suspicious activities

8. Reporting Suspicious Activity

If we suspect or have reasonable grounds to suspect that funds are the proceeds of criminal activity or related to terrorist financing, we will promptly report such activities to the appropriate regulatory authorities as required by law.

9. Policy Compliance

Compliance with this policy is mandatory for all employees. Violations may result in disciplinary action, up to and including termination of employment.

10. Review and Updates

This policy will be reviewed annually or more frequently if required by changes in regulations or business practices to ensure its continued effectiveness.

11. Contact Information

For any questions or concerns regarding this policy, please contact our AML Compliance Officer:

Email: compliance@kuinji.com
Address: 123 Business Avenue, Suite 500, Astana, Kazakhstan