Anti-Money Laundering (AML) Policy

The https://priceactionltd.com/ is operated by Abutor Investments Limited located at Foti Kolakidi, 16, Agia Zoni, 3031, Limassol, Cyprus (Company No.: HE 458981). PriceAction, a digital brand of ABUTOR INVESTMENTS LTD, provides specialized consulting services, including expert analysis and tailored strategies for aspiring traders worldwide. This brand is governed by the officials of Abutor Investments LTD. 

ABUTOR INVESTMENTS LTD. (“the Company”) adopts this AML policy to comply rigorously with the anti-money laundering regulations as outlined in the Prevention and Suppression of Money Laundering Activities Laws of the Republic of Cyprus. The company recognises its responsibility to prevent its financial services from being used for money laundering or financing terrorist activities.

Policy Statement

ABUTOR INVESTMENTS LTD. is firmly committed to the prevention of money laundering, terrorist financing, and the evasion of sanctions. Unwavering compliance with applicable laws and regulations shall serve to safeguard ABUTOR INVESTMENTS LTD’s reputation and uphold public trust in ABUTOR INVESTMENTS LTD.

Policy Objectives

• To establish precise and unambiguous policies for ABUTOR INVESTMENTS LTD. concerning matters of money laundering, terrorist financing, and the avoidance of sanctions.
• To provide clear and concise explanations of the compliance responsibilities that all employees are obligated to fulfill.
• To offer guidance to employees regarding their daily business activities in alignment with legal requirements.
• To foster a work environment that upholds a culture of adherence to legal regulations in the manner in which employees execute their duties.

Definition of Money Laundering

According to Section 2 of THE PREVENTION AND SUPPRESSION OF MONEY LAUNDERING AND TERRORIST FINANCING LAW OF 2007, “laundering offenses” (or money laundering offenses as known internationally), the offenses referred to in Section 4

Again, as per Section 4 of the said law-

“4.-(1) Every person who- 

(a) knows or b) ought to have known that any kind of property constitutes proceeds from the commission of illegal activities and carries out the following activities: 

(i) converts, transfers, or removes such property for the purpose of concealing or disguising its illicit origin or of assisting, in any way, any person who is involved in the commission of the predicate offense to carry out any of the above actions or acts in any other way to evade the legal consequences of his actions; 

(ii) conceals or disguises the true nature, the source, location, disposition, movement, and rights concerning the property or ownership of this property; 

(iii) acquires, possesses, or uses such property; 

(iv) participates in, associates with, co-operates, conspires to commit, or attempts to commit, aids and abets, and provides counseling or advice for the commission of any of the offenses referred to above;

(v) provides information concerning investigations that are carried out for laundering offenses for the purpose of enabling the person who acquired a benefit from the commission of a predicate offense to retain the proceeds or control of the proceeds from the commission of the said offense. 

commits an offense punishable by fourteen years’ imprisonment, by a pecuniary penalty of up to Euro 500.000, or by both of these penalties in the case of 

(a) above and by five years’ imprisonment or by a pecuniary penalty of up to Euro 50.000 or by both in the case of (b) above. 

(2) For the purposes of subsection (1) 

(a) it shall not matter whether the predicate offense is subject to the jurisdiction of the Cyprus Courts or not; 

(b) a laundering offense may be committed by the offenders of a predicate offense as well; 

(c) the knowledge, intention, or purpose which are required as elements of the offenses referred to in subsection (1) may be inferred from objective and factual circumstances; 

(d) No previous or simultaneous conviction for a predicate offense is required, from which the proceeds were derived; 

(e) The identity of the person who committed the predicate offense from which the proceeds were derived is not required to be proven. ”

Policy Framework

• Legal Background: This policy is based on the Prevention and Suppression of Money Laundering Activities Law of 2007, notably Sections 4, 5, 6, 7, and 8​​.
• Laundering Offenses (Section 4): The Company acknowledges that laundering offenses include, but are not limited to, the conversion or transfer of property known to be proceeds of illegal activities, concealing or disguising the illicit origin of such property, and acquisition or possession of such property​​.
• Predicate Offences (Section 5): Defined as offenses criminalized by the laws of the Republic, the company will be vigilant against transactions that may involve proceeds from these offenses​​.
• According to Section 63(2) of the said law, products where the risks of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership, such as certain types of electronic money. Third countries that, on the basis of credible sources such as mutual evaluations, detailed assessment reports, or published follow-up reports, have requirements to combat money laundering and terrorist financing consistent with the revised FATF recommendations and effectively implement those requirements. 

Compliance Obligations

• Customer Due Diligence: Implementing stringent due diligence processes to verify the identity of our clients, understanding the nature of their business activities, and assessing associated risk levels.
• Reporting and Cooperation (Section 4): Mandatory reporting of any activities or transactions suspected of being related to money laundering, in line with the legal obligations outlined in Section 4 of the Cyprus AML law​​.
• Record Keeping and Assessment (Sections 7 and 8): Maintaining comprehensive records of all transactions. The company shall follow the guidelines in Section 7 for assessing proceeds from predicate offences and adhere to the court’s procedures as outlined in Section 8 for inquiries related to the proceeds of illegal activities​​.

Internal Controls and Training

• AML Compliance Officer: Appointment of a dedicated officer to oversee AML compliance, including monitoring transactions and reporting suspicious activities.
• Employee Training: Regular, comprehensive training sessions for employees on AML regulations focus on identifying and reporting potential laundering activities and understanding their legal implications.
• Audit and Monitoring: Regular internal audits and reviews are required to ensure adherence to AML policies and legal requirements. These audits will be in line with Sections 6 and 8, focusing on the acquisition and valuation of proceeds from illegal activities​​.

Policy Review and Amendments

This policy will be reviewed and updated regularly to reflect changes in the Cyprus AML laws and international AML standards. Any amendments will be communicated promptly to all staff members.

Conclusion

ABUTOR INVESTMENTS LTD. commits to upholding the integrity of its financial operations against money laundering and terrorist financing. This policy is a testament to our dedication to legal and ethical compliance, safeguarding our operations, and contributing to the global fight against financial crimes. This detailed policy outlines specific compliance measures and internal controls based on the legal framework of the Republic of Cyprus, ensuring that ABUTOR INVESTMENTS LTD. operates in full compliance with AML laws and regulations.