Sanctions and Anti-Money Laundering Policy
Unitel Group is committed to conducting business ethically while proactively preventing risks related to trade and economic sanctions, as well as money laundering and terrorism financing.
•Engaging, directly or indirectly, in transactions with sanctioned individuals or entities, or assisting others to do so;
•Conducting or supporting transactions with individuals or organizations located in sanctioned countries or regions for profit;
•Using the Group or any affiliated company to launder money, participate in money laundering activities, or provide assistance in such activities;
•Circumventing or violating any laws aimed at preventing sanctions breaches or AML/CFT risks.
General Principles
To ensure compliance with sanctions and anti-money laundering , countering the financing of terrorism(AML/CFT) laws, employees and third parties are prohibited from:
Sanctions Compliance Program
•Before entering any business relationship, the Compliance Department verifies partner information (clients, suppliers, third parties, etc.) against official sanctions lists.
•Sanctions lists include those issued by Mongolia, the United Nations, the European Union, the United Kingdom (including Northern Ireland), and the United States.
•Verification is performed in real-time before initiating business or transactions.
•Based on the verification results, the Compliance Department assesses customer risk and records control explanations and risk levels.
ML / TF Risk Prevention Program
•The Group identifies which parts of the business are subject to AML /CFT regulations and develops compliance programs accordingly.
•All Group companies obligated to comply with AML/CFT laws must perform due diligence on clients, contractors, and other third parties, verifying information against reliable sources.
•After verifying the ultimate beneficial owner, if the individual is found to have political influence, the client will be considered high-risk, and a due diligence review will be conducted.
•For high-risk clients or contractors, detailed due diligence is conducted, and any suspicious or unusual activity is reported to the Compliance Department.