Compliance Control
The key objective of the compliance function is to create a high compliance culture and standards of ethical business standards, as well as an effective regulatory risk management system, which is part of the overall internal control system of the Company. The system is aimed at ensuring strict compliance with the requirements of applicable legislation, internal policies and documents of the Company in order to minimize possible regulatory and reputational risks in the Company's activities, ensure the continuity of the Company's activities in the long term and maintain confidence in the Company on the part of its clients, counterparties and the public as a whole.
In its activities, the Company strives to comply with the best local and international compliance practices, including in anti-money laundering and combating the financing of terrorism and proliferation of weapons of mass destruction.
Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation of Weapons of Mass Destruction
The Company is a financial monitoring entity in accordance with the requirements of the legislation of the Republic of Kazakhstan, and in carrying on its activities ensures compliance with the requirements of the anti-money laundering and combating the financing of terrorism and proliferation of weapons of mass destruction legislation of the Republic of Kazakhstan (hereinafter referred to as AML/CFT).
The Company has formulated and implemented internal regulations that govern the procedure of the ML/FT risk management and implementation of the AML/CFT internal controls:
AML/CFT Policy
Sanctions Compliance
The Company pays special attention to issues of sanctions compliance and observance of applicable sanctions in order to maintain a high level of trust on the part of clients, counterparties, partners, regulators and to ensure that the infrastructure used is protected from possible sanctions risks. For these purposes, the Company:
- Formulated internal policies and implemented procedures to comply with applicable sanctions;
- Applies a comprehensive assessment of sanctions risks of clients, counterparties, transactions and financial instruments;
- Takes reasonable measures to limit or terminate cooperation with clients or counterparties to mitigate the sanctions risk for the Company and the infrastructure used within the framework of applicable legislation.
Anti-fraud and Anti-corruption
The Company has developed measures and implemented control procedures to prevent and combat fraud and corruption, and has organized anti-corruption training for employees.The Company adheres to a zero-tolerance policy towards fraud and corruption in any form and is guided by the following principles in its activities:
- Legality
- Transparency
- Ethics
- Respect for the rights and legitimate interests of partners, employees and clients, protecting them from fraudulent and corrupt practices;
- Avoidance of conflicts of interest.
If you become aware of any cases of corruption or fraudulent actions, abuse of office, or violation of ethics, please send a message to the following e-mail address: [email protected]
Insider Trading and Market Manipulation
The Company shall establish and maintain systems and controls that ensure, as far as reasonably practicable, that the Company and its employees do not commit or assist others in committing acts that may constitute market abuse, including the misuse and dissemination of inside information, market manipulation.
The Company takes all reasonable steps to protect insider information from misuse and to prevent the possibility of market manipulation, including:
- Controls and restricts access to the Company's insider information
- Maintains lists of the Company's insiders; monitors and records insider transactions
- Uses software tools to identify accounts of the Company's employees
- Monitors the Company clients' transactions and orders for market manipulation
Conflict of Interest
A conflict of interest is a situation in which the interests of the Company, its officials, employees and clients do not coincide with each other and/or a situation in which the personal interest of an official or employee of the Company affects or may affect the conscientious and impartial performance of official duties.
The Company uses the following methods to resolve conflicts of interest:
- Priority of the client's interests over the interests of the Company when providing services
- Change or refusal of a transaction/service/product that leads to the arising or implementation of a conflict of interest
- Disclosure of a conflict of interest that has not been excluded
The Company has developed and implemented internal regulations that govern the procedure of organizing a system for managing existing and potential conflicts of interest in the Company.
Data Protection Office
The DPO (Data Protection Office) is a business unit of the Company which responsibilities include protection of clients’ personal data in accordance with the requirements of the Republic of Kazakhstan Personal Data and Its Protection Law dated May 21, 2013 No. 94-V.
If you have any questions regarding the protection and processing of personal data, please contact [email protected]
For Financial Institutions and Counterparties
This section contains the Company's questionnaire forms, which are used both when establishing business relationship and within the framework of current cooperation helping to simplify the interaction process and ensure compliance with regulatory standards.
Wolfsberg W-8BEN-E
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FATCA
The Government of the Republic of Kazakhstan and the Government of the United States of America signed the Agreement to Improve International Tax Compliance on September 11, 2017, which became effective on April 5, 2022. According to the US Foreign Account Tax Compliance Act (hereinafter referred to as FATCA), the Company is registered on the website of the US Internal Revenue Service (IRS):
FATCA Classification — Reporting Model 1 FFI
GIIN - CR1PU0.99999.SL.398 -
CRS
Within the framework of implementation of the Head of State’s instructions on preventing the withdrawal of capital under the guise of foreign exchange transactions, the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan signed the Multilateral Agreement of Competent Authorities on the Automatic Exchange of Financial Account Information (Multilateral Agreement) on June 26, 2018. The Multilateral Agreement is based on Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters (Strasbourg Convention), ratified by the Republic of Kazakhstan Law dated December 26, 2014 No. 267-V ZRK, and provides for the implementation of the Common Reporting Standard (CRS) on financial accounts.
