Anti Money Laundering Policy

Czech Republic has in place the legislative framework governing the area of the prevention of money laundering which is in compliance with the latest EU regulations regarding Anti Money Laundering and Anti Terrorist financing. The Prevention of Money Laundering and Terrorist Financing Act was promulgated in July 2007.
 Pursuant to the Penal Code money laundering is defined as a criminal offence.

Czech Republic has ratified a number of international conventions. In this way Czech Republic has put in place a comprehensive system to detect and prevent money laundering, which has been assessed by the relevant organizations (UN, European Council, European Commission, Financial Action Task Force/FATF) as a modern one and compliant with
international standards.

Main features of The Prevention of Money Laundering and Terrorist Financing Act

  • in accordance with Directives 2005/60/EC and 2006/70/ES defining accountable entities
  • identification and due diligence of clients upon opening of an account or establishing a formal business relationship
  • identification of clients in cash transactions or obviously connected cash transactions in the amount of or exceeding EUR 15,000.00
  • identification of the bearer of the passbook when a transaction on a basis of a passbook or a bearer passbook is made
  • face to face identification except in special cases prescribed by the Ministry of Finance
  • re-identification of clients which are foreign legal persons at least every second year except international governmental organisations
  • identification of clients represented by authorized persons
 reporting to the Office for Money Laundering Prevention of cash transactions of or exceeding EUR 30,000.00
  • option to suspend a transaction or a business relationship as such
  • mandatory appointment of the compliance officer for Anti Money Laundering, professional training, a list of indicators and internal controls
  • 10 years period of keeping records

The Cashila AML Policy is designed to prevent money laundering by meeting the Czech Republic AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

Anti Money Laundering Instructions and Procedure of Cashila addresses the issue of money laundering in accordance with The Prevention of Money Laundering and Terrorist Financing Act, which contains a comprehensive set of measures for detecting and preventing money laundering activities.

  • The AMLIP applies for establishment of new business relationship, acceptance of cash, physical securities or precious metals and any other suspicious transactions.
 – Ascertainment of customer identity is the first stage in the Anti Money Laundering procedure. Client screening and monitoring depends on the classification of the client and statutory requirements and goes from the usual client screening to in-depth due diligence.

  • Cashila reports to the Office for Money Laundering Prevention about cash transaction in the amount and over EUR 15,000.00 on a daily basis and is required to prepare an annual statement on the prevention of money laundering, which is confirmed by the Management Board.

  • Every unusual activity which results in a suspicion of money laundering is reported to the in-house Anti Money Laundering Officer and the Office for Money Laundering Prevention.

  • The establishment of the ultimate economic beneficiary of any accounts, transaction or funds is the second stage.
  • Records of all transaction data and information obtained for the purpose of identification and transactions must be kept for the statutory imposed period
  • The in-house Anti Money Laundering Officer gives internal training to employees on a regular basis by explaining general facts, legal elements and actual tasks of staff in connection with the prevention of money laundering.

Sanctions Policy: Cashila is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Cashila 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 we operate.