Table of Contents

  1. Introduction
  2. Risk Assessment Procedure
  3. The Risk Categories
  4. The Risk Assessment Scale
  5. The Company's Risk Appetite
  6. The Update of Risk Assessment
  7. Model to Identify Customer's Risk Profile

Introduction

This Risk Assessment Policy (Policy) establishes ground for the Company's risk management regarding money laundering and terrorist financing risks.

The Policy is subject to review by the Company's management board at least annually. The proposal for a review and the review of these Guidelines may be scheduled more often by the decision of the MLRO.

The words used in the Policy shall be interpreted in accordance with definitions provided for in the Guidelines, which annex this Policy is.

Risk Assessment Procedure

The Company shall prepare and regularly update the risk assessment in order to identify, assess and analyze the risks of money laundering and terrorist financing related to its activities.

The process of risk assessment, executed by Company shall include at least the following actions:

The risk assessment and the establishment of the risk appetite shall be documented, and the documents shall be updated where necessary.

The Risk Categories