Anti-money laundering policy

Anti-money laundering policy

 NEO Finance adheres to the Money Laundering and Terrorism Financing Prevention Policy in compliance with the laws of the Republic of Lithuania, as well as relevant local and international regulations.

General Information on International Sanctions

International sanctions represent restrictive measures implemented to protect global peace and security.

These measures are enforced by entities such as the United Nations (UN), the European Union (EU), and individual countries like the United States (U.S.) and are directed at states, individuals, and entities found in violation of human rights, engaging in religious, ethnic, or territorial conflicts, supporting terrorism, or breaching international norms and principles.

International Sanctions serve the aim of altering behavior, halting illicit activities, or constraining the actions of the sanctioned state or individual. There are various forms of sanctions, which can include travel bans, asset freezes, restrictions on goods and services such as arms embargoes, targeting specific economic sectors like finance and other areas.

International sanctions implemented by NEO Finance:

UN Sanctions: All member states of the United Nations are obligated to accept and enact resolutions passed by the UN Security Council.

EU Sanctions: Sanctions within the European Union are enforced through EU Council Regulations and hold direct legal force across all EU member states.

U.S. Financial Sanctions: Imposed by Executive Orders from the U.S. President and enforced by the Office of Foreign Assets Control (OFAC) within the U.S. Department of the Treasury.

By complying with U.S. Financial Sanctions, Neofinance complies to good market practices.

International sanction types:

Here are the major types of international sanctions implemented by NEO Finance:

1. Targeted Asset Freezes: These financial sanctions target specific persons and legal entities by restricting their access to funds and assets.

2. Arms Embargoes and Restrictions on Dual-Use Goods are regulatory measures imposed to control the trade and distribution of specific items for security and non-proliferation reasons. Neofinance adheres to embargoes and restrictions imposed by various entities such as EU and U.S.

3. Core Economic Sector Sanctions are aimed at specific sectors of a target country's economy, such as energy, finance, transportation.

Asset freezes and certain sectoral restrictions also extend to legal entities indirectly owned or controlled by designated individuals, even if these entities are not explicitly listed on sanctions lists.

 

Restrictions on enforcing international sanctions.

Due to International Sanctions and internal policies, the company refrains from processing transactions whether directly or indirectly related to countries/regions under comprehensive sanctions by the EU and/or U.S.

In order to ensure compliance with international financial sanctions, Neofinance may suspend transactions and request additional information and/or documentation during the investigation process.

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