Tech View Oü
Anti Money Laundering and Counter Terrorist Financing Policy
The objective of the Policy is to establish the basic principles and general activity guidelines in order
to ensure efficient and proportionate implementation of money laundering and terrorist financing prevention
measures at TECH VIEW OÜ, hereinafter the Company.
The Company is operating under the laws and regulations of the Republic of Estonia and
the European Union. Company is licensed by Estonian Financial Intelligence Unit, license no FVR000325 has been
issued on 05.10.2020.
The money laundering and terrorist financing prevention activities are organised by and are the responsibility
of a member of the Management Board of the Company who is approved by the Financial Intelligence Unit.
Risk based approach
By constant assessment of risks the Company tries to minimise the possibility that its
services could be used for money laundering or terrorist financing.
The Company is guided upon prevention of the money laundering and terrorist financing by the principle of Know
Your Customer. One of the primary prerequisites for the efficient functioning of the principle of Know Your
Customer is the gathering of as precise and as thorough data as possible upon establishment of the customer
relationship. This enables, based on the data provided by the customer, to position the customer's initial
degree of risk.
In order to mitigate risks, information is gathered about the customers which allows to determine the customer
profile and understand the risks associated with the customer and the transactions of the customer. When
identifying the risks, different risk categories are taken into consideration in the aggregate and the degree
of risk is determined for the customer.
The Company has appointed AML Compliance Officer and implemented written AML&CTF
policies, procedures, internal controls as well as systems, which include but are not limited to the
- Establishing risk assessment and risk appetite and maintaining a risk based approach towards assessing
and managing the money laundering and terrorist financing risks to the Company;
- Establishing and maintaining risk-based customer due diligence;
- Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities
- The maintenance of appropriate records for the minimum prescribed periods.
Due diligence measures
The scope of the due diligence measures applicable to the customer depends on the degree
of risk of the customer. Depending on the customer's risk profile the Company applies either simplified,
regular or enhanced due diligence measures.
Prior to opening an account on the Company's website, an adequate KYC process must be
carried out. A risk based approach in implementing KYC account opening procedures is intended to enable the
Company to understand, inter alia, the purpose of the account, the expected activity, to determine the
customer profile and to assess the risks associated with each prospective member.
- In determining risk levels, various factors are considered such as geographic locations, anticipated
balance or activity, PEP etc.
- An enhanced due diligence procedure is carried out for high-risk customers according to the Company's
- KYC questionnaires, at the minimum, include questions regarding the following matters: reason and
purpose of opening the Account, expected activity, its type and frequency, sources of capital and wealth,
occupation of the customer.
The risk-based approach, gathering and updating of data, monitoring of transactions and
analysing of documents certifying the origin of property are the measures which implementation must result
in the creation for the Company of a full picture of the customer and the Company's inner belief that the
customer's activities are legal.
The Company implements the principle of Know Your Customer during the entire customer
The Company is prohibited from transacting with individuals and/or, companies and/or
countries that are on prescribed Sanctions lists. The Company will therefore screen against United Nations,
European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all
jurisdictions in which the Company will operate.
The Company assesses and analyses the risks of money laundering and terrorist financing
on a regular basis and has established detailed instructions to the employees of the Company for money
laundering and terrorist financing prevention. The Company ensures that all employees pass training on the
prevention of money laundering and terrorist financing before commencement of work and provides subsequent
training to them based on necessity, but not less frequently that once annually.