MASAK Compliant KYC Policy and Procedure

 

PR.241 Publication Date: 20.12.2017 | R.OI Revision Date: 23.12.2024 

 

Policy: Preventing Money Laundering and Terrorism Financing

 

A MASAK (Financial Crimes Investigation Board) compliant KYC (Know Your Customer) policy is implemented to prevent money laundering and terrorism financing. This policy aims to verify the identity of all entities doing business, to clearly understand the nature of business relationships, and to be able to detect and respond to unusual or suspicious transactions.

**Purposes:**

  1. Verifying the identity of all parties doing business.
  2. Identifying and evaluating high-risk business partners.
  3. To detect, monitor and report suspicious transactions.
  4. To ensure that relations with business partners comply with MASAK regulations.

 

Procedure: MASAK Compliant KYC Principles

 

  1. Business Partner Risk Assessment

* *Purpose**: To determine risk levels in relations with business partners.  * *Steps. **

  1. **Risk Assessment:** Conduct risk assessment for all business partners. High-risk partners may include:

-Those who only make cash transactions.

-Those who use unusual financial terms or terms.

-Those who use a little-known or remote bank.

-Those who change their bank accounts frequently.

-Those with offices in high-risk countries.

-Those who carry out their transactions through intermediaries.

**Risk Analysis Report Preparation:** Create a report on detected risks and recommended measures.

  1. **Identification of High Risk Partners:** Verify the ultimate owners of these partners (beneficial owner) and the identity of the person being transacted with.

* *Documentation:**

Completed risk assessment reports.

List created according to business partner risk levels.

 

  1. Determination of Ultimate Owners and Representatives

* *Purpose**: To understand the legal ownership structure and representatives of business partners.

Steps:

  1. Identify the ultimate owner and principal agent of the business partner.
  2. For small companies, a trade registry registration or a business license may be sufficient.
  3. Request the identity of the ultimate owner in the following cases:

If KYC measures detect a suspicious transaction (for example, if FATF operates in a high-risk area).

If the identification of the ultimate owner is required by law.

  1. Leverage publicly available information:
  • Such as trade registry records, stock exchange memberships or records of sectoral associations.

* *Documentation:**

  • Ultimate ownership and agency records of high-risk business partners. – Partner credentials.

 

  1. Monitoring Suspicious Transactions

* *Purpose**: To detect and report unusual or suspicious transactions.

Steps:

  1. Set up a system to track all financial transactions (e.g. bills, bank accounts).
  2. Implement automated or manual auditing processes to identify suspicious transactions (unusual money transfers, large cash transactions, etc.).
  3. Report the detected transactions to MASAK.

* *Documentation:**

  • Records and reports on suspicious transactions.
  • E-mails or letters of notifications made to MASAK.

 

  1. Record Keeping and Monitoring

* *Purpose**: To ensure that all KYC processes are documented transparently.

* *Steps:

  1. Store all business partners’ information in an Excel file or financial system that is updated regularly.
  2. Regularly review the risk levels of financial transactions and business partners.
  3. Conduct internal and external audits to audit the effectiveness of KYC procedures.

* *Documentation:**

  • Records containing information of business partners.
  • Financial transaction records (e.g. invoices, financial reports). – Reports of monitoring procedures.

 

  1. Education and Awareness

** Purpose**• To ensure that employees are informed about KYC principles and MASAK regulations.

* *Steps:

  1. Provide training to all employees on KYC policies, suspicious transactions and reporting

processes.

  1. Issue participation certificates after the training.

* *Documentation:**

  • Training program plans and materials. – Participation records and certificates.

 

  1. Review of KYC Procedures

* *Purpose**: To ensure that KYC policies comply with current legal regulations.

Steps:

  1. Review and update KYC procedures annually.
  2. Make changes in accordance with new guidelines of regulatory authorities or MASAK’s publications.

* *Documentation:**

  • Updated policies and procedures.
  • Guidelines from regulatory authorities.

 

Contact Information

To report suspicious transactions or learn about KYC policies:  * *E-mail•** compliance@mioro.com.tr

* *Online Platform:** www.mioro.com.tr/hotline

 

Policy Review

This policy will be reviewed regularly and brought into line with MASAK and international standards.

Last Revised

Date: 23.12.2024

APPROVED BY THE BOARD

OF DIRECTORS

Mioro Gift Shop San. And Trade. Inc.