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Anti-money laundering - AML Policy

Fidulink attaches the utmost importance to the fight against money laundering and the financing of terrorism, both within it and in the projects it supports.

Fidulink is committed to exercising its business objectively, honestly and impartially, ensuring the primacy of the interests of the company, customers and the integrity of the market. This commitment to strict ethical and ethical standards is not only intended to ensure compliance with the laws and regulations in force in the various jurisdictions in which Fidulink operates, but also to earn and keep in the long run. term the trust of its customers, its shareholders, its employees, and its partners.

Fidulink's Charter of Professional Ethics and Professional Ethics (the "Charter") is not intended to list exhaustively and in detail all the rules of good conduct governing its activities and those of its employees in the various countries in which it operates. which Fidulink carries on its business. Its purpose is rather to establish certain guiding principles and rules designed to ensure that its employees have a common understanding of Fidulink's ethical standards and that they practice their profession in compliance with these standards. It aims to reinforce the internal and external credibility of the professionalism of Fidulink's employees.

It is expected that all Fidulink employees (including those working on a secondment or secondment basis) will apply scrupulously and without any pressure the rules and procedures of this Policy in the daily exercise. of their duties, in all responsibility, honesty and diligence.

Money Laundering / Terrorist Financing

Given the nature of Fidulink's business, money laundering and terrorist financing pose specific and significant risks from a legal perspective and the maintenance of its reputation. Compliance with anti-money laundering laws and regulations in the countries in which Fidulink operates is of utmost importance. As a result, Fidulink has developed a program that includes:

  • appropriate internal procedures and controls (due diligence measures);
  • a training program when hiring staff and continuously.

Vigilance measures:

The customer's knowledge (KYC - Know Your Client) implies obligations of identification and verification of the identity of the customer as well as, if necessary, the powers of the persons acting on behalf of the latter, in order to acquire the certainty of dealing with a legitimate and legal client:

  • In the case of a natural person: by the presentation of a valid official document including his photograph. The particulars to be noted and kept are the name (s) - including maiden name for married women, forenames, date and place of birth of the person (nationality), as well as the nature, date and place of issue and the date of validity of the document and the name and quality of the authority or person who issued the document and, where applicable, authenticated it;
  • In the case of a legal person, by the communication of the original or the copy of any act or official register extract dated less than three months noting the name, the legal form, the address of the registered office social identity and the identity of the partners and social leaders mentioned.

In addition, the following information is also required:

  • full address (es)
  • phone numbers and / or GSM
  • email (s)
  • occupation (s)

As well as the following documents:

    • Copy of certified passport
    • Proof of address
    • Curriculum vitae
    • Statement (s) of bank account (s)
    • Bank reference letter
    • Possibly additional identity documents (ID, permit for
      driving, residence permit).

This list is not exhaustive and other information may be taken into account, depending on the circumstances.

Fidulink expects its customers to provide correct and up-to-date information and to inform and promptly make any changes that may occur.

Measures to be applied in case of doubt:

In case of suspicion of money laundering and / or terrorist financing, or in case of doubt as to the veracity or relevance of the identification data obtained, Fidulink undertakes:

    • Not to enter into a business relationship or make any transaction;
    • To put an end to the business relationship, without the need for justification.





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