Chapter I General Provisions
In order to ensure the implementation of the anti-money laundering laws and regulations and internal rules and regulations, and to fully fulfill the anti-money laundering obligations, this system is formulated in accordance with the provisions of the relevant laws and regulations and in conjunction with the actual situation of Youcine.
Article 1: The anti-money laundering mentioned in this system refers to a series of preventive measures formulated and implemented in accordance with the relevant laws and regulations on anti-money laundering with the aim of preventing money laundering activities by criminals through the financial system to disguise and conceal the origin and nature of the proceeds of drug-related crimes, crimes of triad organizations of a triad nature, crimes of terrorist activities, crimes of smuggling, crimes of embezzlement and bribery, crimes of compromising the order of financial administration, crimes of financial fraud and other crimes and their proceeds.
Article 2: Youcine establishes the anti-money laundering leading group, which is fully responsible for planning, organizing, supervising, managing and reporting the internal anti-money laundering work and strengthening contact and communication with the judicial department.
Article 3: The principle of “know your client” shall be followed, and the client identification system shall be implemented with due diligence and care.
Article 4: In accordance with the principles of security, accuracy, integrity and confidentiality, customer identification information and transaction records shall be adequately preserved to ensure that each transaction can be sufficiently reproduced in order to provide the necessary information to identify customers, monitor and analyze transactions, investigate suspicious transaction activities and handle money laundering cases.
Article 5: All Youcine employees must establish a high degree of awareness of anti-money laundering and report any suspicious signs of money laundering to the leading anti-money laundering group in a timely manner.
Article 6: In addition to customer identity and transaction information, the Risk Management Department is responsible for sending and receiving documents, document circulation, training, advertising and preserving information related to anti-money laundering.
Chapter II Organizational structure and responsibilities
The main responsibilities of the anti-money laundering lead group include:
(i)Organizing and planning the anti-money laundering work.
(ii)Organize and implement specific measures for anti-money laundering work.
(iii)Establish and improve the management mechanism of anti-money laundering work by organizing and arranging for the construction of relevant systems and processes.
(iv)Regularly summarize and analyze information and developments in anti-money laundering work and make recommendations.
(v)Organize anti-money laundering trainings.
(vi)Cooperate with regulatory and judicial authorities in the investigation of suspicious transactions.
(vii)Other obligations stipulated by laws, regulations and Company rules and systems.
Article 1: Each department shall strictly fulfill the obligations of anti-money laundering work, and the person in charge of each department shall be the first person responsible for the anti-money laundering work of the department, and the director of internal affairs of the department shall be the executor of the anti-money laundering work of the department. Establish and improve the post responsibility system, to achieve the post, responsibility and person, and the specific situation of the department or post personnel to report to the anti-money laundering leading group in a timely manner.
Article 2: Designate a person responsible for anti-money laundering work, do a good job of customer identification, large sums of money, suspicious transactions should be recorded, analyzed, verified and reported within the stipulated time period, and do a good job of collecting, investigating and returning relevant information.
Chapter III Customer Identification System
Article 1:The Marketing Department shall establish a high degree of awareness of anti-money laundering when registering clients and fully understand the basic information of clients through communication with potential clients, so as to make good use of the first door of client identification. After a customer has successfully signed a contract, the department should maintain regular contact with the customer to understand the latest situation of the customer in a timely manner. If any abnormal situation is detected, we will communicate with the relevant departments in a timely manner.
Article 2: Understand the customer’s identity information, record the basic information of the customer’s identity, and keep valid proofs.
Article 3: Do not conduct business for customers without presenting relevant certificates. No anonymous or false name account shall be processed for the customer.
Article 4: The Commercial Department shall strictly follow relevant legal procedures when handling business for clients.
Article 5:If signs of abnormality are found in the processing of business, the client must be identified again.
Article 6: When fulfilling the obligation of client identification, the following suspicious behaviors should be reported to the organization if found.
(I)The client refuses to provide valid identification documents or other identification documents.
(II)The client refuses to update the client’s basic information without justifiable reasons
(III) After taking the necessary measures, the authenticity, validity and completeness of previously obtained customer identification information are still suspect.
(Iv) Other suspicious behaviors found during the fulfillment of the customer identification obligation.
Article 7: For the duration of the business relationship with a customer, each department shall adhere to the principle of continuous customer identification.
Chapter IV System for the preservation of client identity data and transaction records
Article 1: Client identity information and client transaction records shall be properly preserved in accordance with the principles of security, accuracy, integrity and confidentiality within the prescribed period.
Article 2: The client identity information to be kept includes information and data on the identity of the client.
Article 3: Transaction records that must be kept include data information about each transaction, business vouchers, accounting books and contracts, business vouchers, documents, business letters and other information required by relevant regulations that reflect the actual transaction situation to ensure that they are sufficient to reproduce each transaction.
Article 4: The Commercial Department, with the cooperation and technical support of the Technology Department, shall, within the prescribed period, properly maintain records of customer transactions in electronic files to ensure that they are sufficient to reproduce each transaction.
Article 5: The Finance and Settlement Department shall be responsible for preserving the settlement data of clients’ transactions.
Article 6: Retention period
(I)Client identification data: at least 5 years from the year in which the business relationship ends or the year in which the single transaction is recorded.
(II)Transaction records: at least 5 years from the date the transaction is recorded.
(III)If customer identification information and transaction records involve suspicious transaction activities that are being investigated for anti-money laundering purposes, and the anti-money laundering investigation has not been completed when the minimum retention period stipulated in the preceding paragraph expires, they shall be retained until the end of the anti-money laundering investigation.
(IV) When client identification data or transaction records are kept on the same medium for different retention periods, they shall be kept for the longest period. If the same customer identification data or transaction records are kept on different media, at least one media of customer identification data or transaction records shall be kept in accordance with the above requirements.
Chapter V Large and suspicious transaction reporting system
Article 1 Any suspicious transaction discovered shall be reported to the Anti-Money Laundering Leadership Group in a timely manner.
Article 2 The Company independently develops the anti-money laundering system, which has the function of tracking suspicious and large-value transactions and realizes same-day and historical transaction tracking. It improves the capacity and efficiency of information analysis and screening.
Chapter VI Confidentiality system
Article 1 The staff of each department shall maintain the confidentiality of customer identity data and transaction information obtained by fulfilling anti-money laundering obligations in accordance with the law; they shall not be provided to any unit or individual except in accordance with the provisions of the law.
Article 2 The staff of each department shall maintain the confidentiality of information related to anti-money laundering, such as reporting suspicious transactions and cooperating with the investigation of suspicious transactions, and shall not provide it to customers and other persons in violation of the regulations.
Chapter VIII Anti-money laundering training and publicity system
Article 1：In accordance with the requirements of the money laundering prevention and monitoring system of the law, the company shall conduct continuous anti-money laundering training for its employees. All employees must be trained at least once a year.
Article 2： Content of the training:
(A)the damage caused by money laundering.
(B)anti-money laundering regulations.
(C)How to identify signs of money laundering.
(D)What measures should be taken if risks are detected.
(E)The important role of employees in anti-money laundering work.
Article 3：Strengthen anti-money laundering publicity for customers.
(I)Distribute anti-money laundering publicity materials to customers.
(II)Explain the harm of money laundering and the illegality.
(III) Publicize on Youcine’s official website, APP and other personal media, and change the latest information regularly.