Purpose of Personal Data Collection
IBR-GLOBAL MARKETS LTD Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “IBR-Global Markets Ltd”) is designated to prevent and mitigate possible risks of IBR-GLOBAL MARKETS LTD being involved in any kind of illegal activity.
Both international and local regulations require IBR-GLOBAL MARKETS LTD to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
IBR-Global Markets Ltd covers the following matters:
- Verification procedures.
- Compliance Officer.
- Monitoring Transactions.
- Risk Assessment.
1. Verification Procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, IBR-GLOBAL MARKETS LTD establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
1.1. Identity Verification
IBR-GLOBAL MARKETS LTD’s identity verification procedure requires the User to provide IBR-GLOBAL MARKETS LTD with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes IBR-GLOBAL MARKETS LTD reserves the right to collect User’s identification information for the IBR-Global Markets Ltd purposes.
IBR-GLOBAL MARKETS LTD will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and IBR-GLOBAL MARKETS LTD reserves the right to investigate certain Users who have been determined to be risky or suspicious.
IBR-GLOBAL MARKETS LTD reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, IBR-GLOBAL MARKETS LTD reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
Once the User’s identity has been verified, IBR-GLOBAL MARKETS LTD is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1.2. Card verification
The Users who are intended to use payment cards in connection with the IBR-GLOBAL MARKETS LTD’s Services have to pass card verification in accordance with instructions available on the IBR-GLOBAL MARKETS LTD’s Site.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by IBR-GLOBAL MARKETS LTD, whose duty is to ensure the effective implementation and enforcement of the IBR-Global Markets Ltd. It is the Compliance Officer’s responsibility to supervise all aspects of IBR-GLOBAL MARKETS LTD’s anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users’ identification information.
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
- Monitoring transactions and investigating any significant deviations from normal activity.
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
- Updating risk assessment regularly.
- Providing law enforcement with information as required under the applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, IBR-GLOBAL MARKETS LTD relies on data analysis as a risk-assessment and suspicion detection tool. IBR-GLOBAL MARKETS LTD performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
1) Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
2) Case and document management.
With regard to the IBR-Global Markets Ltd, IBR-GLOBAL MARKETS LTD will monitor all transactions and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when IBR-GLOBAL MARKETS LTD has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Risk Assessment
IBR-GLOBAL MARKETS LTD, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, IBR-GLOBAL MARKETS LTD is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
5. Amendments and Changes
KYC policy may be amended or supplemented at any time, at the discretion of IBR-GLOBAL MARKETS LTD. The user acknowledges and agrees that he must independently check and monitor all amendments and changes in our KYC policy and become familiar with notifications of changes and / or additions to the current policy. If you do not accept the amended or amended KYC policy, you should stop using the Service. Further use of the site and services of the company after changes in policy will be automatically regarded as acceptance of these changes.
This anti-fraud policy is an integral part of IBR-GLOBAL MARKETS LTD agreement, the essence of which is to prevent or partially contain fraud, corruption, collusion, money laundering, terrorist financing and other illegal activities in the activities of IBR-GLOBAL MARKETS LTD. The company is committed to high legal, ethical and moral standards. The public, partners of IBR-GLOBAL MARKETS LTD and Users have the right to expect that we will implement a significant level of protection against any illegal activity. The implementation of the anti-fraud policy was in accordance with applicable local and international legislation.
If a person is justified, the latter is directly or indirectly associated with terrorism, its financing, money laundering or fraud, IBR-GLOBAL MARKETS LTD reserves the right to thoroughly investigate a person using all legal methods and methods specified in the legislation and the contract. The Fraud Commissioner is the first person to detect, investigate and defend against the prevention of prohibited conduct during the user and transaction evaluation process. In some cases, outside researchers may be involved in collecting sufficient evidence and transferring the case to the authorities. The Commissioner to combat fraud is fully responsible for managing third parties. Also, the anti-fraud commissioner is responsible for: Collection of any information relating to the alleged Prohibited Conduct, including information about Users and certain transactions; Conclusion of your findings regarding this case, and reporting them to the management of IBR-GLOBAL MARKETS LTD and the relevant authorities, as well as to any third party, if necessary. The authorized person has the right to open, prosecute, close and report any investigation of the prohibited behavior within his competence without prior notice, consent or intervention from any other person or organization. All investigations will be conducted objectively and confidentially. During the investigation, we reserve the right to block user funds in the account, to ensure prompt and complete investigation procedures. All users under the existing contract are required to cooperate with the Commissioner as quickly and efficiently as possible, including providing relevant information and documentation if the above-mentioned person requests this. All information and documents collected and created during the investigation of prohibited activities that are not yet in the public domain should be kept strictly confidential. The confidentiality of the information collected will be respected both in the interests of the persons concerned and in relation to the integrity of the investigation. The anti-fraud commissioner should only disclose confidential information to individuals or companies who are authorized to receive it, if necessary, in order to conduct an investigation or assist in an investigation.
6. Responsibility of the parties
The Commissioner for Combating Fraud has the primary responsibility for preventing, monitoring and investigating cases of prohibited conduct. According to the above, the company reserves the right to perform the identification of any user or transaction in accordance with the KYC policy in order to identify evidence of prohibited conduct. Based on our anti-fraud policy, we are responsible for:
- Taking appropriate action against persons suspected of a crime or having committed a crime;
- Developing and maintaining effective internal controls to prevent prohibited behavior;
- Conducting operational investigations in case of detection of prohibited conduct or unlawful actions;
- Transmission of information about any suspicions regarding prohibited conduct to the relevant state authorities;
- Ensuring that the Anti-Fraud Commissioner reports on any internal or external suspicions and incidents involving illegal acts.
7. User Statement
Based on all the above, you guarantee that using our service, you do not have the intention to perform any prohibited actions described above. In addition, you agree to any checks in connection with an investigation under the Anti-Fraud Policy, and you agree to cooperate fully and promptly with an anti-fraud commissioner as part of the investigation if necessary.
8. Changes and additions
Our anti-fraud policy may be amended or supplemented at any time, at the discretion of IBR-GLOBAL MARKETS LTD. You acknowledge and agree that you assume the responsibility to periodically check the Anti-Fraud Policy and receive notifications of changes and additions. If you do not accept the amended anti-fraud policy, you should not continue to use the services of the company. Further use of services after the changes imply automatic acceptance of conditions. If you have information about illegal activities or suspicious individuals, please contact our support team.
Every client must cooperate in order for the Company’s anti-crime and anti-terrorism efforts to be successful.