Anti-Money Laundering (AML) Policy

Compliance and Supervisory Procedures
Updated 05.05.2021

Principles and Policies

The AML policy of the Dohrnii Foundation (foundation) is applicable to all staff to help prevent and detect potential money laundering or terrorist financing activity. The foundation takes a zero-tolerance approach to money laundering, terrorist activity and other such financial crimes and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The foundation will ensure it has appropriate policies and procedures in place to complement this AML policy, in compliance with applicable regulations, and monitoring of adherence to those policies will also take place.

All staff will be trained in AML processes and procedures for the foundation and will actively participate in preventing the services of the foundation from being exploited by criminals and terrorists for money laundering or terrorist financing purposes. The objectives of this and related policies are: 

  • ensuring the foundation’s compliance with all applicable laws, statutory instruments of regulation, and requirements of the foundation’s supervisory body; 
  • protecting the foundation and its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements; 
  • preserving the good name of the foundation against the risk of reputational damage presented by implication in money laundering and terrorist financing activities; 
  • making a positive contribution to the fight against crime and terrorism. 

To achieve these objectives, it is the policy of the foundation that:

  • every member of staff shall meet their personal obligations as appropriate to their role and position in the foundation
  • neither commercial considerations nor a sense of loyalty to clients shall be permitted to take precedence over the foundation's anti-money laundering commitment
  • the foundation shall appoint a Money Laundering Reporting Officer (MLRO) and they shall be afforded every assistance and cooperation by all members of staff in carrying out the duties of their appointment;
  • the foundation shall have anti-money laundering policies and procedures outlining the positive actions to be taken by staff during their work, and the MLRO shall keep these under review to ensure their continuing appropriateness.

All efforts exerted will be documented and retained in accordance with the Anti-Money laundering law. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.

Regulation of money laundering in Switzerland is based on two pillars. Firstly, money laundering is a criminal offence punishable by the criminal authorities (Art. 305bis of the Swiss Criminal Code). Secondly, the Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector (Anti-Money Laundering Act, AMLA) requires financial intermediaries to comply with due diligence and disclosure requirements in respect of client transactions. FINMA has issued a detailed ordinance in relation to this Act (FINMA Anti-Money Laundering Ordinance, FINMA AMLO).

At the Moment the foundation is in the process to be affiliated to a self-regulatory organisation authorised and supervised by FINMA.

CUSTOMER INFORMATION VERIFICATION

In verifying customer identity, appointed compliance officers shall review photo identification. The foundation shall not attempt to determine whether the document that the customer has provided for identification has been validly issued.

For verification purposes, the foundation shall rely on a government-issued identification to establish a customer’s identity. The foundation, however, will analyze the information provided to determine if there are any logical inconsistencies in the information obtained. The foundation will document its verification, including all identifying information provided by the customer, the methods used and results of the verification, including but not limited to sign-off by the appointed producer of matching photo identification.

If a customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the appointed agent shall notify the MLRO. The foundation will thereafter decline the application.

Such activity is more commonly known as due diligence / Know Your Customer (KYC) and Know Your Business (KYB).

PREVENTION OF THIRD-PARTY FUNDING, TRANSFER & WITHDRAWAL

The foundation strictly does not allow third party funding. Any funds coming to the account must come from the same account holder. The foundation strictly does not allow transfer of funds between different accounts belonging to different account holders. This is to prevent the possibility of money laundering. The Foundation strictly implements the policy in which withdrawals must be performed only through the same bank account, credit/debit card or digital wallets that client used to deposit the funds. 

RESTRICITED COUNTRIES 

The foundation does not service US and Chinese entities or residents of any kind. While we welcome clients from all over the globe, governmental restrictions along with our foundation policies prohibit probably the foundation from opening accounts originated from the restricted and/or OFAC sanctioned countries.