Node Digital Management Ltd (Nodeam) is committed to abide by and implement a comprehensive set of AML/CFT policies in accordance with sanctions based, internationally recognised guidelines and local regulatory requirements wherever Nodeam and/or it’s other controlled entities will operate from.
Nodeam will account for all applicable guidelines, law, regulations, and sanctions set forth by the Financial Action Task Force (FATF), the United Nations Security Council Resolution (UNSCR), the European Union (EU), the United States of America, and any other jurisdiction with unique requirements where Nodeam operates from.
Nodeam’s AML/CFT and sanctions compliance programme has been designed to identify and mitigate risks to Nodeam’s business activities. The list to follow will provide the basis of the said policy. All staff from Nodeam will be expected to conduct themselves accordingly, if not, to a higher standard.
A non-exhaustive list of inclusions of the said policy are listed below, and will be calibrated as and when required:
1. Conducting Customer Due Diligence (CDD), where required, that incorporates customer identification and verification, and Know Your Customer/Business (KYC or KYB) principles during both onboarding and ongoing monitoring stages of our direct customers or business partners respectively. These principles include screening the direct customers or business partners, and connected parties (including beneficial owners), for Politically Exposed Persons (PEP), adverse or negative media, and against official sanctions lists issued by UNSCR, EU, FATF, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), and, if applicable, of local jurisdictions in which Node conducts its business activities.
2. Adoption of a risk-based approach for conducting enhanced due diligence, where required, on direct customers or business partners assessed to be of higher risk, such as PEPs, or domiciled/residing in high-risk and other monitored jurisdictions identified by the FATF.
3. Establishing processes and systems for ongoing monitoring, where required, to identify suspicious AML/CFT activities or potential sanctions breaches. This can lead to further investigations and the subsequent reporting of such suspicious activities or breaches to the appropriate regulatory authorities.
4. The retention of the abovementioned documentation and records for a period of at least five years.
5. Regular employee training on AML/CFT and sanctions.
6. Nodeam may, in its sole discretion, decide not to commence or continue with any customer/ business partner relationships, process transactions, provide products or services or otherwise facilitate transactions even when permitted by applicable AML/CFT, and sanctions laws and regulations when these activities fall outside of Node’s comfort zone.
7. Nodeam will not serve or engage with any person (legal or natural) as listed in Appendix, except when expressly allowed.
8. By applying for products and services, and by maintaining a relationship or partnership with Nodeam, all customers and business partners, represent and warrant that they shall not use Nodeam in any manner that (a) violate prevailing laws and regulations relating to, but not limited to, AML/CFT and sanctions; and/or (b) involve or for the benefit of sanctioned individuals, entities, countries, or territories.
This AML/CFT Policy Statement supersedes any statement on the same matters previously made by Nodeam and should be view along with the restricted territories list and be regarded as a whole.
Restricted Territories List
1. Nodeam will not offer its services/products to the following sanctioned territories:
- Afghanistan
- Albania
- Congo (DRC)
- Cuba
- Crimea, Donetsk & Luhansk
- Guinea Bissau
- Haiti
- Iran
- Iraq
- Libya
- Mali
- Myanmar
- North Korea (DPKR)
- Russia
- Somalia
- South Sudan
- XVII.Syria
- XVIII.Syrian Arab Republic
- Sudan
- Yemen
- Venezuela
2. Non-sanctioned territories that Nodeam is not offering services/products to:
- USA & Outlying territories
- China (PRC) *
- Hong Kong SAR *
- Japan *
- Singapore *
* Denotes individuals of these territories may be on-boarded but subject to investor classification, and, or enhanced vetting procedures
3. Any sanctioned entities, individuals or activities defined in the body of Nodeam’s Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy Statement.
4. Territories that may trigger enhanced vetting procedures:
- Armenia
- Azerbaijan
- Barbados
- Belarus
- Bosnia-Herzegovina
- Burkina Faso
- Burundi
- Cambodia
- Cayman Islands
- Croatia
- Djibouti
- Eritrea
- Gaza Strip
- Gibraltar
- Guinea
- Jamaica
- XVII.Jordan
- XVIII.Kosovo
- Lebanon
- Montenegro
- Morocco
- XXII.Mozambique
- XXIII.Nicaragua
- XXIV.Nigeria
- North Macedonia
- XXVI.Pakistan
- XXVII.Panama
- XXVIII.Philippines
- XXIX.Senegal
- XXX.Serbia
- XXXI.Slovenia
- XXXII.Tanzania
- XXXIII.Turkey
- XXXIV.Trinidad & Tobago
- XXXV.Tunisia
- XXXVI.Uganda
- XXXVII.United Arab Emirates
- XXXVIII.Vanuatu
- XXXIX.Western Sahara
- Zimbabwe
NB: The lists provided herein may be changed without prior notification.