AML & KYC POLICIES
Meta Luminor c/o Web Consulta Limited (also known as Meta Luminor or The Company) is a key business introducer and consultancy whose licensed partners are committed to the highest standards of the compliance and Anti-Terrorist Financing and requires the management, and employees to follow the named standards.
Money laundering – the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.
The process of money laundering can be divided into three sequential stages:
Placement. At this stage funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by The Company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing.
Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.
Integration. Funds get back into circulation as legitimate to purchase goods and services.
AML Policy
Meta Luminor c/o Web Consulta Limited, No.2 , LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta, like most companies providing key business introducing and consultancy services does not make compliance or AML decisions but allows for the supply side licensed partners to conduct necessary AML review with their internal compliance teams which adheres to the principles of Anti-Money Laundering and actively prevent any actions that aim or facilitate the process of legalising of illegally gained funds. All clients are reviewed by the internal compliance of the licensed entities with whom the client is ultimately onboarded. The AML policy is in place to act as a guide and means preventing the use of The Company’s and their supply side partner service providers by criminals, with the aim of money laundering, terrorist financing or other criminal activity.
For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by all supply side licensed entities together with The Company. Moreover, Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta has no right to report clients that the service providers or law enforcement bodies are informed on their activity. The Company’s supply side licensed partners reserve the right to suspend any service to client’s, which can be regarded as illegal or, may be related to money laundering in the opinion of the their internal staff.
Company’s procedures
Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta will make sure that it is dealing with a real person or legal entity prior to providing the necessary consultancy or key business introduction. Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta together with its partners performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities. The AML policy is being fulfilled by various supply side licensed partners that Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta introduces clients to by means of the following:
know your customer policy and due diligence
monitoring of client activity
record keeping
Know Your Customer and Due Diligence
Because of The Company’s and their licensed partners commitment to the AML and KYC policies, each client of The Company has to finish a verification procedure. Before Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta starts any cooperation with the client, The Company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The Company as well as their supply side licensed partners apply heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.
Individual clients
During the process of registration, each client provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and city code. A client sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary by most supply side partners for the client to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:
As a standard, a high-resolution copy of the first page of local or international passport, where the photo and the signature are clearly seen, OR another official ID with the same requirements. The indicated documents must be valid at least 6 months from the filing date.
Corporate clients
In case the applicant company is listed on a recognised or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required but this decision can only be made by supply side licensed partners internal compliance officers. In case the company is unquoted and none of the principal directors or shareholders already has an account with any of the supply side licensed companies that Meta Luminor c/o Web Consulta Limited, 474, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta, introduces them to, the standard documentation requested by most licensed partners in general would require that the client provides the following documents because of the requirements of KYC:
a high-resolution copy of the certificate of incorporation/certificate OR means to prove the existence of the company: e.g. company name and registration number for verifying the ownership on the company registry);
This procedure is performed to establish the identity of the client and to also allow Meta Luminor c/o Web Consulta Limited, 474, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta know/understand the clients and their corporate structures prior to introducing the client to the supply side licensed partners and to be able to provide the best consultancy services of The Company.
Monitoring of client activity
In addition to gathering information from the clients, Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta supply side licensed partners continue to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. Meta Luminor c/o Web Consulta Limited, No.2, LG Office 1, Triq Ir-Rundun, Mellieha, MLH2307, Malta, supply side licensed partners also implement systems of monitoring named transactions (both automatic and, if needed, manual) to prevent using their services by criminals.