PRIVACY POLICY

Our Privacy Policy

 

We are committed to protecting your privacy. The following privacy policy describes who we are, and how we collect, store, use, and share your personal information. In case of a complaint, please contact us or the supervisory authorities. Moreover, we explain how to contact us in the event of a complaint or how to contact the supervisory authority. personal information about you is collected, used, and managed by us.

 

Key terms

Here are some key terms used in this policy that may be helpful to explain:

 

About Us– Card Elite by ULTIMAX MARKETING MANAGEMENT CO.LLC  program Manager of  Via Carte International –   financial institution that acts as the issuer of the E-Money Accounts, E-Wallets, and/or Cards, regulited by Visa Credit License 10077680.

Data Protection Officer Can be reached at office@card-elite.com.

Personal Information Any information relating to an identified or identifiable individual.

Your personal information is collected by us.

Please note that we may collect and use the following personal information from you:

·       Information about yourself, including your name, email address, and telephone number;

·       You should provide information regarding your business, including the URL(s) of your website and your company's name and number;

·       Our website collects information about how you use it.

It is necessary for us to collect this Personal Information in order to communicate with you regarding the products and/or services we can provide you. In the event you fail to provide that personal information, we may be unable to contact you in order to assist in the performance of the contract we have or are trying to enter into with you (for example, in order to supply you with products and/or services).


The way we collect your personal information

The majority of the Personal Information we collect comes directly from you, through telephone calls, social media messages, emails, and/or our website and apps. Additionally, we may collect information about:

·       Sources that are publicly available, such as Social Media or Companies House;

·       By third parties, e.g., sanctions screening companies, credit reference agencies, due diligence companies;

·       With your consent, such as from your bank or building society;

·       Please see our cookies policy for more information on our use of cookies; and

·       We monitor our websites through our IT systems, for example: computer networks, internet connections, CCTV and access control systems, communications systems, email, and instant messaging.

What we do with your personal information and why

In accordance with data protection law, we may only use your Personal Information when we have a valid reason to do so. Our legal basis for using your personal information is as follows:

·       Providing you with our products and/or services requires us to process your Personal Information;

·       To determine which of our products/services might be of interest to you, we are required to process your data for the legitimate business interests pursued by us; and

·       The processing of your information is necessary to comply with a legal obligation to which we are subject (such as screening for sanctions and verifying your identity and identifying you).

The only time we rely on consent as a legal basis for processing your Personal Information is when we send direct marketing communications to you via email or text message. Please contact us (see below) if you would like to withdraw your consent at any time.

Your personal information is collected and processed for the following purposes:

·       You will receive products and/or services from us;

·       Ensure that customer records are updated;

·       Ensure that our systems are protected from unauthorised access and modification;

·       Analyze financial performance, client base, and type of work to help us manage our business.

What we do with your personal information

The following parties receive Personal Information from us on a regular basis:

·       Among ultimax's subsidiaries;

·       Our third-party partners (e.g., financial institutions, credit card schemes, and other payment schemes) help us deliver our products and/or services to you;

·       Using marketing agencies or website hosts to help us run our business; 

·       Those who have been approved by you as third parties.

In order to ensure that your Personal Information is protected, we only allow our service providers to handle it. Likewise, we impose contractual obligations on service providers to ensure that your Personal Information can only be used to provide you and us with services.

To comply with our legal and regulatory obligations, we may disclose and exchange information.

Some Personal Information may also be shared with other parties, such as potential buyers of some or all of our business or during a reorganization. Sometimes, anonymization is not possible, but it is usually the case. A confidentiality agreement will be in place between the recipient and the sender. No other third parties will have access to your personal information.

 

The length of time we will keep your personal information

You can expect us to retain your Personal Information for as long as necessary in order to fulfill the purposes for which it was collected, as well as to comply with any legal, regulatory, accounting, or reporting obligations.

Taking into account the amount, nature, and sensitivity of your Personal Information, the potential harm caused by unauthorized use or disclosure, the purposes for which we process your Personal Information, whether those purposes can be achieved through other methods, and the applicable legal and regulatory requirements, we determine the appropriate retention period for your Personal Information.

Whenever it becomes unnecessary to retain your Personal Information, we will anonymize it.

 

Exiting the European Economic Area with your personal information

Depending on the purposes described above, we may transfer Personal Information collected from you to a third-party data processor, vendor or hosting partner located outside of the European Economic Area (“EEA“) or to a member of our group of companies. The EU Commission has determined that the transfer of your personal information to a country that ensures an adequate level of protection for your personal information is the only way we will transfer your information outside the EEA, or if we have put in place adequate safeguards as required by the applicable data protection law. You can reach us for more information by clicking on 'How to contact us').

 

Your rights

 

These rights are free of charge to you:

Access– A copy of your Personal Information may be requested (the right of access).

Rectification– If there is a mistake in your Personal Information, you are entitled to request that it be corrected.

Erasure– In certain circumstances, you have the right to request that we delete your Personal Information.

Data portability– A structured, commonly used, and machine-readable format of the Personal Information you provided to us and/or the right to transmit that data to a third party.

Restriction of processing– If you contest the accuracy of your Personal Information, for example, you have the right to request that we restrict processing of your Personal Information.

To object– In certain situations, you may object to our continued processing of your Personal Information, such as processing carried out for our legitimate interests, at any time. – the right to object to direct marketing (including profiling).

The right not to be subjected to automated decision-making- Being protected from being subjected to decisions based solely on your appearance. The automated processing of data (including profiling). A legal effect on you or one that significantly affects you in some way.

Withdraw consent– You have the right to withdraw your consent to us processing your personal information. If we are processing your Personal Information, you can withdraw consent at any time. As long as you consent.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see more information in the link: ttps://www.gov.il/en/departments/policies.

Please follow these steps if you would like to exercise any of those rights:

·       You can contact us by email, phone, or letter;

·       Please provide us with enough information to identify you (for example, your full name, address and more information);

·       Please provide us with proof of your identity and address (credit card bill, a recent utility bill or a copy of your passport  or driver's license);

·       Please specify the right you wish to exercise and the information you require.

Protecting your personal information

Our security measures prevent personal information from being accidentally lost, misused, or accessed by unauthorized persons. Any suspected breach of data security is also handled according to our procedures. A suspected data security breach will be reported to you and any applicable regulator if we are legally required to do so.

 

How to complain

If you have any questions or concerns about how we use your personal information, we hope we can resolve them.

Additionally, you have the right to lodge a complaint with a supervisory authority, regardless of where you work, live, or where an alleged violation of data protection laws occurred. The supervisory authority in Israel is The Privacy Protection Authority who may be contacted at https://www.gov.il/en/departments/policies.

Changes to this privacy policy

It is possible for us to change this privacy notice at any time – any changes will be posted on our website or notified to you by email, for example.C

Our AML Policy

Financial institutions and closely related entities such as crypto wallets and exchanges experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Card Elite (hereinafter referred to as “We” (“Us”, “Our”) or the “Firm”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the www.card-elite.com (hereinafter the “Website”) are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to our strategy and program.

The firm has strict and transparent standards and continuously strengthens firm’s processes to ensure compliance with applicable AML laws and regulations.

Ucom Bank reserves the right to reject any customer, payment or business that is not consistent with the AML policy subject to the requirements of the applicable AML laws and regulations.

 

Adherence to applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide us an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to us additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

 

Monitoring For Suspicious Activity

 

Our AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, we may request information regarding the transactions carried out through the customer’s account opened at card-elite.com and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, we also reserve the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

 

Prohibitions

Ucom Bank has no AML risk appetite for customers who engage in any of the following:

§  Intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;

§ Repeated unintentional or repeated accidental breaches of AML laws;

§  Misusing the account for the purpose of money laundering or terrorism financing;

§  Misusing the account for the purpose of other fraud;

§  Facilitating business activities which could be construed as a tax offence;

§  Refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in our AML policy.

Ucom Bank intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that we may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions 

The firm has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

We also have no appetite to execute transactions relating to any such natural person or legal entity being included in:

§  The United Nations Security Council Sanctions List (UN);

§  The Consolidated List of European Union Financial Sanctions (EU);

§  Sanction lists administered by the United States Office of Foreign Assets Control (OFAC),

§  Including the List of Specially Designated Nationals and Blocked Persons;

 

§  Any other sanctions list.

In addition, we pay particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

The firm has the assigned Compliance officer who is responsible for implementation of our AML policy, including but not limited to, of the above listed activities

Our AML Policy

Financial institutions and closely related entities such as crypto wallets and exchanges experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Card Elite (hereinafter referred to as “We” (“Us”, “Our”) or the “Firm”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the www.card-elite.com (hereinafter the “Website”) are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to our strategy and program.

The firm has strict and transparent standards and continuously strengthens firm’s processes to ensure compliance with applicable AML laws and regulations.

Ucom Bank reserves the right to reject any customer, payment or business that is not consistent with the AML policy subject to the requirements of the applicable AML laws and regulations.

 

Adherence to applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide us an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to us additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

 

Monitoring For Suspicious Activity

 

Our AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, we may request information regarding the transactions carried out through the customer’s account opened at card-elite.com and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, we also reserve the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

 

Prohibitions

Ucom Bank has no AML risk appetite for customers who engage in any of the following:

§  Intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;

§ Repeated unintentional or repeated accidental breaches of AML laws;

§  Misusing the account for the purpose of money laundering or terrorism financing;

§  Misusing the account for the purpose of other fraud;

§  Facilitating business activities which could be construed as a tax offence;

§  Refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in our AML policy.

Ucom Bank intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that we may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions 

The firm has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

We also have no appetite to execute transactions relating to any such natural person or legal entity being included in:

§  The United Nations Security Council Sanctions List (UN);

§  The Consolidated List of European Union Financial Sanctions (EU);

§  Sanction lists administered by the United States Office of Foreign Assets Control (OFAC),

§  Including the List of Specially Designated Nationals and Blocked Persons;

 

§  Any other sanctions list.

In addition, we pay particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

The firm has the assigned Compliance officer who is responsible for implementation of our AML policy, including but not limited to, of the above listed activities

Our AML Policy

Financial institutions and closely related entities such as crypto wallets and exchanges experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Card Elite (hereinafter referred to as “We” (“Us”, “Our”) or the “Firm”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the www.card-elite.com (hereinafter the “Website”) are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to our strategy and program.

The firm has strict and transparent standards and continuously strengthens firm’s processes to ensure compliance with applicable AML laws and regulations.

Ucom Bank reserves the right to reject any customer, payment or business that is not consistent with the AML policy subject to the requirements of the applicable AML laws and regulations.

 

Adherence to applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide us an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to us additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

 

Monitoring For Suspicious Activity

 

Our AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, we may request information regarding the transactions carried out through the customer’s account opened at card-elite.com and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, we also reserve the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

 

Prohibitions

Ucom Bank has no AML risk appetite for customers who engage in any of the following:

§  Intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;

§ Repeated unintentional or repeated accidental breaches of AML laws;

§  Misusing the account for the purpose of money laundering or terrorism financing;

§  Misusing the account for the purpose of other fraud;

§  Facilitating business activities which could be construed as a tax offence;

§  Refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in our AML policy.

Ucom Bank intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that we may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions 

The firm has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

We also have no appetite to execute transactions relating to any such natural person or legal entity being included in:

§  The United Nations Security Council Sanctions List (UN);

§  The Consolidated List of European Union Financial Sanctions (EU);

§  Sanction lists administered by the United States Office of Foreign Assets Control (OFAC),

§  Including the List of Specially Designated Nationals and Blocked Persons;

 

§  Any other sanctions list.

In addition, we pay particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

The firm has the assigned Compliance officer who is responsible for implementation of our AML policy, including but not limited to, of the above listed activities

Our AML Policy

Financial institutions and closely related entities such as crypto wallets and exchanges experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Card Elite (hereinafter referred to as “We” (“Us”, “Our”) or the “Firm”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the www.card-elite.com (hereinafter the “Website”) are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to our strategy and program.

The firm has strict and transparent standards and continuously strengthens firm’s processes to ensure compliance with applicable AML laws and regulations.

Ucom Bank reserves the right to reject any customer, payment or business that is not consistent with the AML policy subject to the requirements of the applicable AML laws and regulations.

 

Adherence to applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide us an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to us additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

 

Monitoring For Suspicious Activity

 

Our AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, we may request information regarding the transactions carried out through the customer’s account opened at card-elite.com and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, we also reserve the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

 

Prohibitions

Ucom Bank has no AML risk appetite for customers who engage in any of the following:

§  Intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;

§ Repeated unintentional or repeated accidental breaches of AML laws;

§  Misusing the account for the purpose of money laundering or terrorism financing;

§  Misusing the account for the purpose of other fraud;

§  Facilitating business activities which could be construed as a tax offence;

§  Refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in our AML policy.

Ucom Bank intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that we may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions 

The firm has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

We also have no appetite to execute transactions relating to any such natural person or legal entity being included in:

§  The United Nations Security Council Sanctions List (UN);

§  The Consolidated List of European Union Financial Sanctions (EU);

§  Sanction lists administered by the United States Office of Foreign Assets Control (OFAC),

§  Including the List of Specially Designated Nationals and Blocked Persons;

 

§  Any other sanctions list.

In addition, we pay particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

The firm has the assigned Compliance officer who is responsible for implementation of our AML policy, including but not limited to, of the above listed activities

Our AML Policy

Financial institutions and closely related entities such as crypto wallets and exchanges experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Card Elite (hereinafter referred to as “We” (“Us”, “Our”) or the “Firm”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the www.card-elite.com (hereinafter the “Website”) are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to our strategy and program.

The firm has strict and transparent standards and continuously strengthens firm’s processes to ensure compliance with applicable AML laws and regulations.

Ucom Bank reserves the right to reject any customer, payment or business that is not consistent with the AML policy subject to the requirements of the applicable AML laws and regulations.

 

Adherence to applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide us an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to us additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

 

Monitoring For Suspicious Activity

 

Our AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, we may request information regarding the transactions carried out through the customer’s account opened at card-elite.com and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, we also reserve the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

 

Prohibitions

Ucom Bank has no AML risk appetite for customers who engage in any of the following:

§  Intentional or willfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;

§ Repeated unintentional or repeated accidental breaches of AML laws;

§  Misusing the account for the purpose of money laundering or terrorism financing;

§  Misusing the account for the purpose of other fraud;

§  Facilitating business activities which could be construed as a tax offence;

§  Refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in our AML policy.

Ucom Bank intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that we may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions 

The firm has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

We also have no appetite to execute transactions relating to any such natural person or legal entity being included in:

§  The United Nations Security Council Sanctions List (UN);

§  The Consolidated List of European Union Financial Sanctions (EU);

§  Sanction lists administered by the United States Office of Foreign Assets Control (OFAC),

§  Including the List of Specially Designated Nationals and Blocked Persons;

 

§  Any other sanctions list.

In addition, we pay particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

The firm has the assigned Compliance officer who is responsible for implementation of our AML policy, including but not limited to, of the above listed activities