Information about internal policy adopted by Frontline Panthers regarding prevention of money laundering
Money laundering can be defined as introducing property values to economic turnover that benefit from a criminal act in order to give them a semblance of a legal origin. This practice is closely linked to criminal activities, usually in the most dangerous dimension, having in fact often organized character.
In order to prevent money laundering, Poland, like many other countries, has introduced to its legal system a law aiming to counteract money laundering as well as terrorist financing. Legal rules of the Act, along with provisions of other regulations having international character, which Poland is a party, specify rules and obligations relating to the prevention of money laundering.
The issue of anti-money laundering and counteracting terrorism has been regulated in the Act of 16 November 2000 on counteracting money laundering and financing terrorism (Journal of Laws No. 116, item. 1216, consolidated text of 16 March 2010., OJ . No. 46, pos. 276).
The policy covers, in particular:
- keeping a record of transactions made through the Frontline Panthers platform that value exceeds the equivalent of EUR 3,000.00, even if the transaction is carried out by more than one operation, where circumstances indicate that they are related to each other and were divided into operations of less value with the intention of avoiding the obligation to register;
- keep appropriate records for at least 5 years from the date of registration of the transaction;
- use financial security toward users of the platform, including the identification of the user. The scope of an application is determined on the basis of risk assessment of money laundering and terrorist financing, made as a result of the analysis, including in particular the type of user of the Website, business relationships, products or transactions;
- the introduction of the suspension of transactions, block of individual user accounts and freeze the assets deposited on them;
- ensuring the participation of employees performing duties related to prevention of money laundering and terrorist financing in Frontline Panthers in training programs related to these obligations.
We additionally inform that in the case of referral to Frontline Panthers (by any state authority of Polish Republic, European Union or any other body appointed on the basis of an international agreement, which Republic of Poland is a party) of any ruling, which implies of the obligation to keep or transfer to a deposit account of the above institution user’s cash or cryptocurrency. In this case the account of the user can be suspended and accumulated funds sent to the previously mentioned deposit account or blocked for duration of the ruling. The same consequences will occur while blocking bank account where Frontline Panthers’s funds are deposited, basing on any act of the above mentioned body or institution. In this case, Frontline Panthers advises the user of the reason for blocking access their funds within 7 days, starting from the date when blocking took place. Frontline Panthers at the explicit request of the relevant authorities and agencies and upon presentation of relevant required documents, has the right to share user’s date to above described institutions.
Frontline Panthers reserves the right to not making transactions with entities located on the sanctions list conducted by the relevant institutions dealing with the prevention of money laundering, in particular in the framework of the United Nations, the European Union and the Office of Foreign Assets Control of the US Treasury Department (OFAC).