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This doc describes Coolorca.com, Inc (CoolOrca LTD, Spyorca.com, LLC Foxnetstore) set of rules and pledges to identify and discourage illegal activities aimed at supporting terrorism in every possible way money laundering through goods and services sold on the CoolOrca platform.

TERMINOLOGY

The phrase "money laundering" means engaging in any activity or transaction that has the purpose of keeping secret the origin of finances derived from illegal transactions, including all types of fraud and terrorism. The crimes involving money laundering are identified and monitored by national legislation.

The money-laundering procedure includes the following provisions:

Arrangement. Depositing cash into accounts at banks and financial institutions; converting money into other financial instruments; using cash to purchase high-value items for subsequent resale. Launderers often look for simplified and less demanding methods of placing cash in order to make these funds "clean" afterward, to erase their history. Smurfing refers to a placement format in which multiple small cash deposits are created at banks whose countries have lax requirements. Smurfing allows Launderers to create many small cash deposits instead of one large one. In this way, the fraudsters circumvent the generally accepted rules applicable to cash interactions.

Multilayered. Separation of finances from a criminal activity from their source via multilevel financial procedures (money transfers between institutions, secured loans, early annuities, letters of credit with forged documentation) in order to conceal the true source of money. Launderers plan to send money by changing both its location and its form. The goal is to prevent law enforcement from tracing the dirty money.

Integration. It means putting laundered money back into the country's economy in such a way that it is recognized as legitimate money.

This set of rules is supplemented by several programs that help support the following directions:

  • Acceptance of risk-based tactics.

  • A policy of close customer acquaintance and adherence to rules when contacting customers.

  • Absolute control of client activity.

  • Maintaining reports and records.

RISK-BASED APPROACH

Identification of potential money laundering risks related to customers and their actions enables the CoolOrca administration to choose and apply the best measures to monitor and minimize these types of risks. Among the underlying risks are the following:

COUNTRY RISK

Combined with other risk factors, it provides valuable insights into possible money laundering tactics. Other factors that also make it easy to identify a potentially dangerous country include:

  • Countries for which any prohibitive measures apply, including embargoes, restrictions, sanctions. 

  • Countries identified by FATF experts as unwilling to contribute to the fight against money laundering and featuring no appropriate regulations and legal provisions.

  • Countries identified by verified sources as dangerous, supporting terrorist activities.

CLIENTS RISK

There is no unanimous opinion on potentially dangerous categories of clients to date. Nevertheless, the following parameters may allow us to consider a client as a risk associated with the risk of money laundering. These are the following:

  • Arms manufacturers.

  • Clients doing business with active involvement of large sums of money.

  • Charities and other non-profit organizations whose activities are not regulated.

SERVICE RISK

Identification of money laundering risks in connection with the provision of services must necessarily consider such factors as services established by regulators, government agencies, or other stable, verified sources, as potentially carrying a high risk of money laundering.

KNOW YOUR CLIENT AND APPLY DISCRETION WHILE DEALING WITH HIM 

CoolOrca features a brokerage organization working online. Therefore, all relationships between this organization and its clients are not fixed face-to-face. Instead, CoolOrca uses digital information brokers in conjunction with other verification tools to strictly verify customers (their identity and trustworthiness) to guarantee identity verification. These techniques are also used to verify customer documents and obtain background information about the customer, the purpose of his presence on the platform, and the main interactions with him.

CoolOrca obtains all information about customers, assessing their risk concerning possible money laundering.

CoolOrca is obliged to determine whether each customer is acting on his/her own behalf or on behalf of another natural or legal person. An important rule when servicing a client is to obtain evidence of his/her identity or of the intermediaries acting on his/her behalf promptly. The nature of the confidential arrangements should also be determined.

MONITOR CLIENTS ACTIONS

Apart from initial customer verification, CoolOrca rules require further monitoring of customer activities to identify any potentially dangerous actions, including fraud. The surveillance system is based on both manual and automated tracking. Such a comprehensive approach has proven to be excellent. Client accounts are also monitored and analyzed according to several criteria.

CoolOrca itself has developed and implemented the process of reporting on potentially risky activities. It complies with the regulations and the law thus all CoolOrca employees can inform the person responsible for fund laundering reports if they have information about specific individuals (support of terrorism, funds laundering). The process involves the following steps:

  1. Staff must track and monitor all potentially dangerous or unusual transactions.

  2. Reporting of potentially dangerous transactions and activity must comply with general jurisdiction rules.

  3. Specialists responsible for fund laundering reporting shall be notified of unauthorized transactions monthly.

REPORTS AND RECORDS 

It is essential to maintain records and retain all documentation generated to verify the identity of customers and assess the details of each monetary transaction and other activity that may be potentially related to money laundering. This includes unauthorized activity report files, AML account tracking documents, and others. This information is maintained for at least 5 years.


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