1. General Statement
TUADV OÜ (hereinafter – the “Company”), registered in Estonia at Harju maakond, Tallinn, Pohja-Tallinna linnaosa, Telliskivi tn 57, 10412, is committed to preventing money laundering, terrorist financing, and other illegal activities in accordance with the laws of Estonia, EU regulations, and international standards.
This Anti-Money Laundering Policy (hereinafter – the “Policy”) defines our procedures and responsibilities to ensure that all financial operations of the Company are lawful and compliant with applicable legislation.
2. Anti-Money Laundering (AML) Policy
2.1. Purpose
The Company applies strict measures to ensure that its services are not used for money laundering, terrorist financing, fraud, or any other illegal purposes.
2.2. Scope
This Policy applies to all clients, partners, and transactions, including:
- payments for advertising services;
- commission remuneration received by the Company for participation in third-party affiliate programs, in accordance with the terms of such programs;
- any financial operations conducted through payment systems or cryptocurrency exchanges.
The Company does not administer its own affiliate programs and does not make commission payments or other remuneration to third parties or individuals within affiliate programs. The Company may only receive commission remuneration from partner services in accordance with the terms of their affiliate programs.
2.3. Procedures
- Monitoring and reviewing transactions for unusual or suspicious activity;
- Maintaining detailed documentation of all payments and client identification documents;
- Conducting regular internal audits and risk assessments.
The Company accepts payments only for its own advertising and marketing services or receives commission remuneration from third-party affiliate programs and does not make financial payouts or transfers of funds to third parties.
3. Know Your Customer (KYC) Procedures
To comply with KYC requirements, the Company collects and verifies personal and business information of clients and partners before establishing financial relationships. This includes:
3.1. Personal information
- full legal name;
- date of birth;
- residential address;
- identification documents (passport, ID card, driver’s license, etc.).
3.2. Business information
- company name, registration number, and legal address;
- information about directors and ultimate beneficial owners (UBO);
- company website, description of activities, and trade names.
3.3. Verification
- All documents are verified through official registries or reliable sources;
- Clients and partners may undergo additional verification if transactions appear suspicious or high-risk;
- Only verified accounts may receive services and conduct financial transactions.
4. Sanctions Screening
4.1.
The Company conducts screening of clients and partners against international and national sanctions lists, including:
- European Union sanctions lists;
- United Nations Security Council sanctions;
- OFAC (United States);
- HM Treasury sanctions (United Kingdom).
4.2.
Clients, partners, and transactions are automatically screened before cooperation begins and periodically during the business relationship.
4.3.
Services are not provided or are blocked for individuals or organizations included in sanctions lists.
5. Reporting Suspicious Transactions
5.1. Detection
The Company monitors transactions for unusual activity, sudden increases in transaction volume, or actions inconsistent with the client’s business profile.
5.2. Internal reporting
Any employee who identifies a suspicious transaction must immediately report it to the responsible AML officer.
5.3. External reporting
Where required by law, the Company reports suspicious transactions to the Estonian Financial Intelligence Unit (FIU) or other competent authorities.
5.4. Confidentiality
All reports and investigations are confidential and disclosed only to authorized personnel and regulatory authorities.
6. Record Keeping
6.1.
The Company maintains:
- client identification and verification documents;
- transaction records;
- sanctions screening and risk assessment results;
- suspicious transaction reports.
6.2.
Documents are retained for at least 5 years after the end of the business relationship, in accordance with Estonian legislation and international standards.
7. Employee Training
7.1.
All employees receive regular training regarding:
- AML and KYC procedures;
- recognition of suspicious activity;
- sanctions compliance;
- reporting rules for suspicious transactions.
7.2.
Employees are required to comply with this Policy at all times.
8. Policy Review and Updates
- This Policy is reviewed at least once per year or when significant changes occur in legislation, business processes, or the Company’s risk profile.
- Updates are approved by Company management and communicated to responsible personnel.
9. AML Contact Information
For questions or clarifications regarding this Policy:
Email: info@tuadv.com
Address: Harju maakond, Tallinn, Pohja-Tallinna linnaosa, Telliskivi tn 57, 10412