Compliance AML

Compliance & Risk Manual

Version 1.1 Date 22.11.2020

LeverIT Panama S.A., a company incorporated under the laws of Panama, registered at the (Mercantile) Record No 1647356-1-674939 D.V.60, Panama City, Republic of Panama.

Compliance & Risk Management

LeverIT Panama S.A. take compliance matters extremely seriously and are committed to managing risks of the different business areas. LeverIT Panama is regularly refining and strengthening its controls, to address evolving risks and threats.

Regulators globally have made substantial progress by agreeing new global standards that will prevent virtual assets and Virtual Asset Service Providers (“VASPs”) from being misused for transactions with links to crime or terrorism. To that end, one of the key missions for LeverIT Panama is to significantly reduce money laundering and terrorist financing risks through the development of a robust Anti-Money Laundering (“AML”) Programme.

LeverIT Panama has no tolerance for knowingly, or through willful negligence, facilitating activities related to money laundering, terrorist financing or financial crimes more broadly. LeverIT Panama will not enter into, or maintain, business relationships with customers who LeverIT Panama has identified as outside of its AML risk-tolerance, or who have been identified as, or are associated with, sanctioned parties.

LeverIT Panama’s AML Programme articulates its commitment to take reasonable measures to detect and deter money laundering, terrorist financing, and other financial crimes. Additionally, it outlines LeverIT Panama’s commitment to comply with economic and trade sanctions administered and enforced by governments and supranational bodies.

Transaction screening is another effective way to detect accounts that LeverIT Panama suspects may involve the proceeds of crime including, but not limited to, activities related to child abuse, darknet markets, sanctions, terrorist financing, scams and stolen funds. LeverIT Panama will make appropriate filings to relevant authorities and place restrictions on accounts where necessary.

LeverIT Panama will continue to implement appropriate processes to mitigate and alleviate risks posed to the business and address evolving Regulatory requirements.