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ANTI-MONEY LAUNDERING POLICY

1. Purpose and Scope

FLORN LIMITED (“the Company”)—registered at PERIKLEOUS, FLAT/OFFICE 103, STROVOLOS 2020, NICOSIA, CYPRUS—has a robust Anti-Money Laundering (AML) program overseen by Director and Compliance Officer, Sofia Michailidou. Our objective is to prevent and detect any form of money laundering (ML) or terrorist financing (TF). This policy complies with:

  • European Union AML Directives (4th, 5th, 6th) and related regulations;
  • United States laws (Bank Secrecy Act, USA PATRIOT Act, FinCEN guidelines);
  • Brazilian Law No. 9,613/1998, as amended;
  • FATF (Financial Action Task Force) Recommendations; and
  • Cyprus AML legislation (Prevention and Suppression of Money Laundering and Terrorist Financing Laws of 2007–2021).

1.1 Corporate Structure and Applicability

Branches / Economic Group: FLORN LIMITED currently has no branches and is not part of an economic group. This AML Policy applies to all of our operations.

Affiliates or Subsidiaries: Should the Company expand in the future (e.g., opening affiliates/subsidiaries), the same AML requirements outlined herein will automatically apply to all new entities.

2. Zero Tolerance and Compliance Program

FLORN LIMITED strictly prohibits ML or TF, maintaining a zero-tolerance stance toward illegal financial activities.

We operate under a Compliance Program directed by Sofia Michailidou (Compliance Officer), who supervises policy updates, training, and regulatory liaison.

AML policies and procedures are reviewed annually or earlier if there are significant regulatory or internal changes.

3. Prohibition of Shell Banks

FLORN LIMITED does not open accounts for or transact with shell banks.

Internal controls are designed to detect and refuse any transaction that might involve shell banks, preventing indirect access to our systems or products.

4. Politically Exposed Persons (PEPs)

Board/Ownership: The Company has not had any PEP in its ownership or board of directors within the past five years.

PEP Hiring / Engagement: Should FLORN LIMITED hire PEPs, their close associates, or family, we conduct enhanced due diligence (EDD) and obtain senior management approval before onboarding.

PEP Customers: We apply heightened scrutiny to any account belonging to a PEP or their family members, from onboarding through ongoing monitoring.

5. Risk-Based Assessment and Due Diligence

Know Your Customer (KYC): We gather valid government-issued identification, proof of address (as needed), and verify authenticity (e.g., through credit bureaus or official databases).

Risk Profiling: We classify customers based on a risk-based approach, updating and reviewing these profiles periodically.

Expected Transaction Patterns: Our AML team analyzes and documents the normal, expected transaction patterns for each customer. We investigate discrepancies that may indicate suspicious activity.

Enhanced Due Diligence (EDD): High-risk customers (e.g., PEPs, high-volume transactions, or customers from FATF-flagged jurisdictions) undergo more intensive verification, including negative media checks and beneficial ownership screening.

Customer Information Updates: General customer records are updated at least annually, while high-risk customer data is reviewed more frequently to reflect any changes in ownership, business activities, or potential risk factors.

6. Transaction Monitoring and Reporting

Suspicious Activities: We employ manual and automated systems to monitor for red flags (e.g., unusual transaction sizes, multiple structured deposits, involvement of higher-risk entities).

Suspicious Activity Reports (SARs): The Compliance Officer promptly files an SAR with the relevant Financial Intelligence Unit—e.g., MOKAS (Cyprus), FinCEN (US), COAF (Brazil)—if suspicious activity is identified.

Mandatory Reporting: FLORN LIMITED ensures that any transaction meeting the criteria for legal reporting is submitted to the authorities without delay.

7. Data Protection and Confidentiality

GDPR Compliance: We maintain strict data protection measures consistent with the General Data Protection Regulation (GDPR) and relevant local regulations. Detailed internal procedures govern the storage, processing, and retention of customer data.

Record-Keeping: All CDD and transaction records are retained for at least five (5) years (or longer if legally required).

8. Training and Communication

Regular Training: AML training is mandatory for all employees upon hiring and occurs annually thereafter. Updates or refreshers are scheduled if significant regulatory changes happen.

Dedicated Reporting Channels: We maintain an internal hotline and a dedicated email at compliance@florn.net for reporting potential AML concerns anonymously and promptly.

No Retaliation: FLORN LIMITED prohibits retaliation against any person who raises a concern in good faith.

9. Non-Compliance and Disciplinary Measures

Internal Investigations: The Compliance Officer promptly investigates any alleged breach of AML policy.

Disciplinary Actions: Violations may lead to disciplinary measures (including termination) and, where applicable, notification to law enforcement or other regulatory bodies.

10. Review Cycle

Annual Review: This AML Policy is reevaluated every year or when major changes occur in AML legislation or Company structure.

Continuous Improvement: Feedback from staff, partners, and regulators is encouraged to enhance these procedures.