CONTACT

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POLICIES

International

HOW International (trading via the following companies: MGAP London LLP, Partnership No. OC403646, and MGAP London Intelligence Limited, Company No. 13770863) has developed the following Guidance to make sure that we constantly and rigorously:

• use our own customer identification program (CIP) to verify the customer's identity using credentials like their name, date of birth, address, national insurance and social security numbers as well as other available data and documents;

• perform customer due diligence (CDD) to collect all available customer’s credentials to verify their identity and evaluate their risk profile; where the risk profile is higher than normal, we also use enhanced due diligence (EDD) procedures developed internally as a part of our business asset search and debt recovery practice;

• perform continuous monitoring of our partners activities; as we know that checking your customer once isn’t sufficient to ensure security, where understanding their typical activity / modus operandi and monitoring it allows us to catch irregularities and eliminate risks as they arise.

Our KYC procedure on our clients, investors, project partners and service providers is based on the following guideline principals:

• we use most powerful comparable data resources for our KYC checks, inclusive of PEP checks lists, AML/CFT global regulatory framework data, as well as OFAC (for the USA), OFSI (for the UK) and the EU consolidated sanctions lists and regimes;

• we aim to verify our customer’s identity and the nature of their financial dealings by assessing their credentials before allowing them to go into business with us;

• we do not allow any direct or indirect involvement of any clients, investors, partners or service providers from the following restricted and/or sanctioned countries: North Korea, Iran, Syria, Cuba, Sudan (Republic of Sudan or North Sudan), South Sudan (Republic of South Sudan) and Russian Federation (including the regions of Crimea, Donbas and Lugansk areas);

• we do not perform any transactions on behalf of any third parties, i.e another individual or organisation.

The above helps us to understand our customers’ and partners’ general financial habits; having those necessary procedures in place allows us to catch any abnormalities, and effectively mitigate and manage risks associated with financial criminal infiltration, money laundering, terrorism financing, identity theft, human trafficking and more.

For and on behalf of HOW International

Sergey Grachev
CEO