Anti-Money Laundering Policy

Introduction

Avaro is wholly committed to the fight against money laundering. As part of our commitment to combat and eliminate money laundering, we have implemented an educational program for all personnel to complete during their initial training. This program focuses on the fundamentals of Anti-Money Laundering (AML) and our internal Compliance Procedures.

Having successfully completed the internal program, all clients are required to read, acknowledge and act in accordance with Avaro’s “Anti-Money Laundering & Compliance Procedures Manual.

Definition

Money laundering is the term used for the concealment of illegally obtained money, typically by means of transfers involving foreign banks and legitimate financial institutions.

Principles

The key principles of the “Anti-Money Laundering Statement” are that:

1. Avaro will maintain a written document of AML policy and procedures and a system of internal controls to ensure ongoing AML compliance by a designated person(s) and to take appropriate action, once suspicious activity is detected.

2. Avaro will comply with applicable anti-money laundering & terrorist financing laws and regulations wherever possible.

3. Avaro’s anti-money laundering policies apply to all business units and departments.

4. Protect Avaro from money laundering & terrorist financing.

5. All identified suspicious activities must be reported to the extent of all applicable foreign and domestic laws.

6. All the Client’s related documents will be preserved for a period that will not be less than five (5) years or in accordance with law requirements.

7. Avaro will cooperate fully with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws in the event that there is cause to believe that a breach in AML procedures has occurred.

8. Avaro commits to no withdrawal being actioned from ANY Client account without full and satisfactory ‘know your customer’ or ‘compliance and due diligence’ checks being carried out. This means that any documentation required must be supplied in order to proceed with the return of funds to the Client.

9. Funds will always be returned to the initial source of funding. In simple terms if you have deposited via a wire transfer the funds will be returned via wire transfer; if you have used a Visa card, funds will be returned to the Visa card. At no point will Avaro deviate from this.

Should you have any further questions regarding the Anti-Money Laundering policy, email our support team or contact us via our online chat for further clarification or assistance.