AML Policy

Limited Liability Company «TMY» Anti-Money Laundering Policy.

TYM participates in the fight against the legalization of illegal income. As part of our regulatory commitment and our efforts to combat the legalization of proceeds of crime, we have appointed an employee responsible for enforcing this policy.

TYM requires all personnel to be trained in the area of anti-money laundering and our internal compliance procedures.

Financial monitoring officer ("MLRO"). The functions of the financial monitoring officer are to receive all reports of suspicious activity by the staff.

This employee is responsible for implementing the procedures set out in this anti-money laundering Policy, determining the need for and extent of reporting suspicious activity to the national Bank of the Republic of Georgia ("NB"), responding to NB requests, and resolving any issues or controversies arising from this Policy.

TYM has developed four main policies to help identify, prevent, and report illegal income laundering activities:

1) customer awareness Policy (“KYC”),

2) Policy identification of the beneficial owner (“BOV”)

3) Policy of monitoring suspicious activity

4) Policy for developing systems, management tools, and training

The legislation of Georgia on combating the legalization of illegal income on the territory of Georgia, as well as throughout the world, admits the use of professional services for the legalization of such income.

Thus, laws on countering the legalization of illicit income and the financing of terrorism in these jurisdictions are extended beyond the traditional regulated institutions, including independent lawyers and proxies, service providers.

Legislation on combating the legalization of illegal income in the territory of Georgia is mainly reflected in Law No. 2391, dated 06/06/2003 “On assistance in preventing the legalization of illegal income”.

The provisions of the Law create mandatory requirements for: identifying the name and identity of your client or investor and maintaining proper records of such verification; maintaining proper records of transactions with investors or clients for a minimum period of at least 5 years; internal control and reporting procedures, including training employees to prevent the legalization of illegal income, as well as the appointment of a financial monitoring officer. Failure to comply with the Law is a serious offense.

Brief description of the main principles of the TYM company on fight against legalization of illegal income: TYM protection from money laundering and financing of terrorism.

Maintaining policies and procedures to combat the legalization of illegal income and the financing of terrorism, internal control systems to ensure compliance with current legislation in this area by the designated person (persons) and taking appropriate measures when suspicious activity is detected by submitting data on such transactions in accordance with the guidelines established by the National Bank of Georgia.

Compliance with existing laws and regulations on combating the legalization of illegal income and the financing of terrorism established by Georgian legislation.

TYM's anti-money laundering policy applies to all business entities. Notification of all detected suspicious activities to the extent required by all applicable foreign and domestic laws.

Storage of all client documents for the period specified by the legislation of Georgia. TYM does not offer services for opening anonymous accounts.

Fully cooperate with law enforcement and regulatory authorities to the extent permitted by all applicable laws. Training of employees in the "know your customer" and "fight against the legalization of illegal income" methods and new laws and regulations on countering the legalization of illegal income.

For more information about our anti-money laundering Policy, please contact us by email.