Mindium Ltd

Company registration number: 14345808

Office address: Ingleby House, 11 Cannon St, Birmingham B2 5EN

Registered office address: Suite B Fairgate House, 205 Kings Road, Birmingham, West Midlands, United Kingdom, B11 2AA

With this Anti-Money Laundering Policy, Mindium Ltd aims to prevent the use of its services in criminal activities, such as money laundering and the financing of terrorism.

Since Mindium Ltd makes direct payments to the bank accounts/card of our contractors, we need to be sure that we do not expose them and ourselves to the risks of involvement in illegal activities.

The main part of our AML policy is the Know Your Customer procedure. KYC protects Mindium Ltd from doing business with organizations or individuals involved in illegal activity, such as money laundering, terrorist financing or corruption.

Everyone who wants to work as our contractors shall provide AML Compliance Officer with:

– Identity Proof (Passport or Driving Licence);

– Address Proof (Electricity Bill, Bank Account Statement, Gas Bill, rent receipt, etc.);

– Other necessary documents.

The information provided by potential contractors is then checked for authenticity and compared with official lists to identify persons suspected of involvement in criminal activity, bribery or money laundering;

clarify in respect of which jurisdiction companies or individuals are subject to international sanctions;

identify politically exposed persons (PEP).

Our AML policy is implemented using a risk-based approach. AML Officer analyse information from public data sources, private data sources from third parties and sanctions lists published by governments or territories as well as documents directly provided by the translator to uncover any potential risk for Mindium Ltd.

Risk factors include:

The potential contractor appears to be a resident of a high-risk region. Mindium Ltd is prohibited from working with individuals, companies and countries that are under international sanctions.

The potential contractor is reluctant to provide information necessary to establish their identity, conceals the identity or provides documents posing doubts on their veracity, authenticity, etc.

The potential contractor does not respond to e-mail messages, and it is difficult to contact them.

The potential contractor uses TOR network services, constantly connecting from IP addresses in different countries.

The potential contractor has a questionable background (including prior criminal convictions) or is the subject of news reports indicating possible criminal, civil or regulatory violations.

AML/KYC procedures are never complete, as potential contractor risk level can change. To detect suspicious activity and conduct a follow-up investigation if the situation requires, our AML Officer monitors transactions and keeps the information obtained during KYC up-to-date.

In case of protection of the interests of Mindium Ltd, if there’s an investigation into one of our contractors, we are obliged to share their data to law enforcement authorities. For more information about how we collect and process personal data, please refer to our Privacy Policy.

The list of countries under sanctions:

Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea-Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russia, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states).