Effective: January 2025
Omnes Technology AG and its affiliates (we, us, our, or Omnes Group) take a zero-tolerance approach to involvement illicit / illegal activity. Omnes Group complies with its legal obligations by ensuring reasonable steps have been taken to carry out anti-money laundering (AML) screening procedures, including know your client (KYC), know your business (KYB), and customer due diligence (CDD), in order to prevent and avoid money laundering, identity theft, terrorism financing, financial fraud, and other financial crimes.
Our AML screening procedures include gathering customers’ personal information (both of natural and legal persons) by means of application forms, questionnaires followed by live identification using best-in-class digital KYC solutions. Following the verification of our client, our AML system, using third-party KYC databases, will screen the client to ensure such client is not a politically exposed persons (PEP) or appearing on a sanctions list.
Our AML procedure involves a risk scoring system that is able to identify suspicious activity. If a transaction is flagged by this system, it is put on hold and our client is asked to provide additional AML and KYС verification as an enhanced due diligence (EDD) measure.
In the event a cl does not pass our AML/KYC screening procedures, the clients transaction are put on hold and a report is submitted to the Money Laundering Reporting Office Switzerland (MROS).
Omnes Group has adopted a risk-based approach to combating money laundering and terrorist financing. Our risk-based approach, allow us to ensure that any measures to prevent or mitigate money laundering and counter terrorist financing (CTF) are commensurate to the risks identified. The risk-based approach allows resources to be directed in accordance with priorities so that the greatest risks receive the highest attention.
Omnes Group at all times reserves its right to appoint third-party service providers to fulfil any element of its AML procedure, including KYC, KYB, AML, CTF, CDD, EDD, and PEP screening. Our third-party service provides must at all times comply with our Privacy Notice in relation to our client’s personal information.
Omnes Group can share a client’s personal information, collected as part of our AML procedure, with the competent authorities upon receiving a legitimate request to do so.
Omnes Group will not enter a business arrangement with prospective client who is suspected of, or involved directly in, money laundering.
Our AML procedure is designed to ensure compliance with applicable AML regulations, including the:
We review and update our AML practices on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for changes in regulation and our business.
All staff of Omnes Group are required to be familiar our AML procedures. Our staff duties with respect to our AML. procedures include monitoring our compliance with our stated AML procedures on a continuous basis in order to identify the risk of money laundering and terrorist financing.
Omnes AML procedure is in accordance with international standards, consisting of two-point verification on people and assets, in different stages of the client life-cycle, including On-Boarding Screening, Periodic Review Screening, and Suspicious Transaction Screening.
Omnes reserves the right to investigate certain clients or transactions which have, in Omnes‘ sole discretion, been deemed high risk or suspicious.
Where it is reasonably deemed that any client information is incorrect, inaccurate, outdated, or incomplete, Omnes has the right to request further information from that client in order to satisfy it‘s AML procedure, or to terminate the provision of services to the client.
Omnes is prohibited from providing services to natural or legal persons that are on prescribed sanctions lists. Omnes therefore screens all client against sanctions lists of the United Nations, European Union, United Kingdom HM Treasury, and the United States Office of Foreign Assets Control (OFAC).
All clients of Omnes Group will undergo identity verification to as a standard AML/CTF measures by means of:
account onboarding (On-Boarding Screening):
periodic reviews (Periodic Review Screening):
at any time following suspicious or irregular transactions by way of continuous transaction monitoring (Suspicious Transaction Screening):
Omnes works with third party AML solution providers to verify documentation and information received as part of its AML procedure.
Omnes takes further steps to verify identification through face-to-face meetings, and / or live video authentication meetings, and / or correspondence during any On-Boarding Screening, Periodic Review Screening, or Suspicious Transaction Screening.
Face-to-face and live video
When face-to-face meetings or live video authentication meetings takes place, the following measures should be adhered to by us:
In certain instances where identification documents can be accessed through reliable online databases, the above procedures may not be followed by way of exception.
The information will be collected, stored, shared, and protected strictly in accordance with the Omnes Privacy Notice and related regulations.
Correspondence only
When identity verification takes place solely through correspondence and without face-to-face or live video authentication meetings, copies of the original identification documents must be provided in original certified form. Where related to a Swiss legal or natural person, certified by a Swiss notary public, or other means by which such certifications are usually issued such as a Swiss attorney at law, a Swiss financial intermediary supervised under AMLA, and where related to a legal or natural person of another jurisdiction, the equivalent of the aforementioned din such jurisdiction.
Beneficial ownership and control
Natural person
Where the client is a natural person, and there is no reason to doubt that the client is also the beneficial owner (BO) of the client, the client may record a confirmation of BO status in a memorandum addressed to Omnes. Alternatively, the client must provide a written declaration addressed to Omnes declaring the BO.
Legal person
Where the client is a legal person, it will be required to provide the identification of the:
The client must provide a written declaration addressed to Omnes declaring the above.
Omnes reserves the right to request additional BO information depending on the type of legal form of the client and the information shared by the client.
PEP
A PEP can be an individual who holds a prominent public position or function, either domestically or internationally, which may include:
PEPs may also include family members and close associates of these individuals, as their positions can present higher risks for potential involvement in bribery, corruption, or money laundering. Financial institutions and other entities are typically required to apply enhanced due diligence measures when dealing with PEPs to mitigate risks associated with their transactions.
A client must clarify whether the client, the BO, or authorized representative of any of the aforementioned, is a PEP.
EDD
Enhanced due diligence is specifically designed for dealing with high-risk or high-net worth clients and large transactions, as these clients and transactions pose greater risks from an AML/CTF perspective.
Where a client is transacting substantially above the average transaction size, as determined by Omnes, has been identified as or related to a PEP, or triggered the internal high-risk factors list, the client’s transaction must be paused for EDD. As part of EDD, Omnes will conduct an enhanced due diligence process whereby additional documents and information may be requested form the client.
Continuous monitoring for Suspicious Transaction Screening
By way of Suspicious Transaction Screening, Omnes carries out continuous transaction monitoring Omnes utilises data analysis as a risk-assessment and suspicion detection tools for KYT. Omnes performs a range of KYT related compliance checks, including data collection, filtering, record keeping, investigation, and reporting.
In accordance with Omnes Suspicious Transactions Screening findings, Omnes reserves the right determine whether any transactions is suspicious or bona fide. Where Omnes determines a transaction as suspicious it reserves the right to file an MROS report.
Omnes has appointed a duly authorized compliance officer whose duty is to ensure the effective implementation and enforcement of this AML Policy. It is the compliance officer’s responsibility to supervise all aspects of this AML Policy.
The compliance officer is entitled to interact with law enforcement and investigating officers mandated to supervise AML/CTF, and other illegal activity.
Omnes provides AML/CTF training to all employees who will be dealing with clients or will be involved in implementing this AML Policy.
If you have questions or comments about our AML procedures, you can contact us by email at: [email protected]
Any changes we make to this AML Policy will be shared on our website, and where appropriate, notified to you by email.