AML Policy
Anti-Money Laundering & Counter-Terrorism Financing Policy
1. Policy Statement
ILYA BIG STAR LIMITED LIABILITY COMPANY is committed to preventing money laundering and terrorist financing. We comply with all applicable regulations including the Act of March 1, 2018 on Counteracting Money Laundering and Financing of Terrorism (OJ 2020, item 971 with amendments) and maintain robust AML/CTF procedures in accordance with Polish and European Union law.
2. Core AML Principles
Know Your Customer (KYC)
No relationship with customers can be established before completing identification procedures and providing reliable information about identity, citizenship, occupation, and sources of wealth.
Client Risk Segmentation
Customers are classified by risk level (Low, Medium, High) for implementing appropriate measures and controls to mitigate risks.
Transaction Monitoring
Ongoing monitoring of business relationships and transactions using IT systems to detect suspicious activities and patterns.
Suspicious Reporting
Mandatory reporting of suspicious transactions to the General Inspector and prosecutor as required by Polish law.
3. Prohibited Counterparties
The Company will not accept the following categories of counterparties:
4. Customer Due Diligence Levels
Low Risk Customers - Simplified CDD
EU residents, third countries with low corruption levels:
- • Basic document verification
- • Standard sanctions screening
- • Limited PEP checks
- • Basic transaction monitoring
Medium Risk Customers - Standard CDD
Standard business relationships:
- • Detailed identification procedures
- • Thorough source of wealth analysis
- • Standard PEP checks
- • Regular transaction monitoring
High Risk Customers - Enhanced CDD
High-risk countries, PEPs, suspicious activities:
- • Enhanced identification and verification
- • Detailed source of funds documentation
- • Senior management approval required
- • Continuous intensive monitoring
5. High-Risk Jurisdictions
The following jurisdictions are identified as high-risk according to European Commission regulations:
6. Money Laundering Risk Indicators
High-Risk Transaction Indicators
- • Regular transfers from high-risk countries
- • Transfers to areas close to terrorist organizations
- • Numerous transactions just below reporting thresholds
- • Anonymous bank account usage
- • Incompatible transactions with customer profile
Customer Behavior Indicators
- • Unusual or suspicious identification documents
- • Refusal to provide required documentation
- • Business structure that doesn't make economic sense
- • Legal proceedings due to criminal activities
- • Frequent changes in bank account details
7. AML Training Requirements
AML Officer Training
- • Annual external course (minimum 30 hours)
- • Continuous professional development
- • Specialized compliance certifications
- • Regular updates on regulatory changes
Staff Training Program
- • Annual internal training (minimum 20 hours)
- • Role-specific compliance modules
- • Regular testing and certification
- • Incident reporting procedures
8. Reporting Obligations
We are required to report the following to Polish authorities:
- • Transactions exceeding EUR 15,000 (within 7 days)
- • Suspicious money laundering/terrorist financing activities (within 2 days)
- • Transactions from crimes other than ML/TF (within 96 hours)
- • Currency exchange transactions above EUR 15,000
- • Cross-border wire transfers and payment information
9. Three Lines of Defense
First Line
President & Management Board
Second Line
AML Officer & Compliance Team
Third Line
Internal & External Auditors
10. Record Keeping
We maintain comprehensive records for a minimum of 5 years as required by EU regulations:
- • Customer identification documents
- • Transaction records and monitoring reports
- • Suspicious activity reports
- • Risk assessment documentation
- • Training records and certificates
- • Internal investigation reports
- • Correspondence with authorities
- • Sanctions screening logs
11. Company Information
ILYA BIG STAR LIMITED LIABILITY COMPANY
ILYA BIG STAR SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
ul. Michała Kleofasa Ogińskiego, nr 11, lok. 9
03-318 Warszawa, Poland
KRS: 0001070217 | NIP: 5223278580 | REGON: 527002360
12. Contact Information
Compliance Officer: compliance@bigstar-pay.pl
General Inquiries: info@bigstar-pay.pl
Whistleblower Reports: Anonymous reporting available through compliance channel
Policy Version: 1.0
Approved by: ARNOLDS KALNIŅŠ, President of Management Board
Last updated: September 13, 2024
Next review: September 13, 2025