Anti-Money Laundering (AML) Policy

1. Introduction

AmaJova LTD ("Company" or "AmaJova") is a company incorporated under English law. AmaJova operates a freelance marketplace that enables companies to find and hire individual specialists for specific jobs, while freelance specialists can apply for positions that match their skills. Contractors cooperate with employers remotely through the platform.

AmaJova is committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML) regulations. Although AmaJova is not registered as a Money Services Business (MSB) with the Financial Conduct Authority (FCA), the Company has implemented AML policies and procedures designed to deter illicit activities, protect its users and the business, and safeguard the integrity of the financial services community. The Company complies with the Money Laundering Regulations and relevant guidance.

2. Purpose

This policy outlines AmaJova's measures to prevent the use of its platform for money laundering, terrorist financing, or other illicit activities. It is designed to ensure compliance with applicable laws and regulations while fostering a safe and trusted environment for its users.

3. Scope

This policy applies to:

- All users of the AmaJova platform (individual and institutional).

- All employees, consultants, officers, owners, and directors of AmaJova.

- All geographic locations where AmaJova operates.

4. Key AML Measures

AmaJova employs a risk-based approach to AML compliance, implementing the following measures:

4.1 Know Your Customer (KYC) Policies

- KYC procedures are designed to form a reasonable belief about the true identity of the Company's customers.

- Verification is conducted through third-party vendors, Civic Technologies and Persona Identities Inc.

4.2 Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

- Risk-based tiers are established for user verification.

- Enhanced checks are conducted for high-risk customers, including obtaining and verifying Ultimate Beneficial Ownership (UBO) information when required by law.

4.3 Reporting Suspicious Activities

- Suspicious Activity Reports (SARs) are filed when suspicious activities are identified.

- Examples of suspicious transactions include those inconsistent with a user’s known business or personal activities.

- The Compliance Officer investigates and determines the need for filing SARs and maintains related records.

4.4 Transaction Monitoring

- A robust transaction monitoring program identifies unusual or suspicious activity.

- Rule-based systems are used to flag and freeze potentially suspicious transactions for further review.

4.5 Training and Audits

- Regular training is provided to employees on AML policies and practices.

- Internal audits or independent third-party reviews assess the effectiveness of AML measures.

5. Sanctions Compliance

AmaJova fully complies with global sanctions requirements to prevent its platform from being used for prohibited transactions. Measures include:

- Screening customers against global and domestic sanctions lists, including:

    - The UK Sanctions List

    - Financial sanctions targets by regime (OFAC, EU, UN, etc.).

- Regularly updating sanctions lists and conducting ongoing monitoring.

- Freezing accounts and transactions linked to sanctioned individuals or entities and reporting to relevant authorities.

5.1 Restricted and Sanctioned Countries

AmaJova prohibits conducting business with individuals or entities located in or associated with the following countries and regions:

- Afghanistan

- Belarus

- Burundi

- Central African Republic

- Chad

- Congo Republic

- Crimea

- Cuba

- Democratic Republic of the Congo

- Donetsk People’s Republic

- Eritrea

- Iraq

- Iran

- Libya

- Lugansk People’s Republic

- Myanmar

- North Korea

- Somalia

- South Sudan

- Sudan

- Syria

- Russia

- Venezuela

- Yemen

These restrictions are in place to comply with global sanctions and to prevent any activities that could violate international laws or regulations.

6. Governance and Oversight

- The Compliance Officer oversees the implementation and enforcement of AML policies.

- The Compliance Officer reports to senior management and ensures regular policy updates and compliance reviews.

- Policies are reviewed and updated annually or as required by regulatory changes.

7. Data Protection and Privacy

AmaJova is committed to protecting customer data in compliance with GDPR and other applicable data protection laws. Measures include:

- Secure storage and processing of user information.

- Limiting access to sensitive data to authorized personnel only.

- Transparent communication with users about data collection and usage.

8. Reporting and Cooperation

AmaJova cooperates fully with law enforcement and regulatory authorities. This includes:

- Timely response to law enforcement requests.

- Providing information and assistance during investigations.

- Ensuring compliance with all relevant reporting obligations.

9. Prohibited Practices

AmaJova prohibits:

- Doing business with shell banks.

- Allowing transactions with sanctioned individuals or entities.

- Engaging in activities that circumvent global sanctions or AML regulations.

10. Conclusion

AmaJova is dedicated to fostering a safe and compliant platform for its users. By implementing robust AML measures, the Company aims to protect its business, users, and the financial community from exploitation by criminals.

This policy was drafted and certified by the Chief Compliance Officer of AmaJova and is subject to regular review to ensure alignment with evolving regulatory requirements.