AML / KYC Policy

Pulaski Publicity LTD Anti-Money Launderingand Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) isdesignated to prevent and mitigate possible risks of Pulaski Publicity  being involved in any kind of illegalactivity.


Both international and local regulationsrequire Pulaski Publicity to implement effective internal procedures andmechanisms to prevent money laundering, terrorist financing, drug and humantrafficking, proliferation of weapons of mass destruction, corruption andbribery and to take action in case of any form of suspicious activity from itsUsers.


AML/KYC Policy covers the following matters:


Verification procedures.

Compliance Officer.

Monitoring Transactions.

Risk Assessment.

Verification procedures

One of the international standards forpreventing illegal activity is customer due diligence (“CDD”). According toCDD, Pulaski Publicity LTD establishes its own verification procedures withinthe standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification


Pulaski Publicity’s identity verificationprocedure requires the User to provide Pulaski Publicity with reliable,independent source documents, data or information (e.g., national ID,international passport, bank statement, utility bill). For such purposesPulaski Publicity reserves the right to collect User’s identificationinformation for the AML/KYC Policy purposes.


Pulaski Publicity will take steps to confirmthe authenticity of documents and information provided by the Users. All legalmethods for double-checking identification information will be used and PulaskiPublicity reserves the right to investigate certain Users who have beendetermined to be risky or suspicious.


Pulaski Publicity reserves the right to verifyUser’s identity on an on-going basis, especially when their identificationinformation has been changed or their activity seems to be suspicious (unusualfor the particular User). In addition, Pulaski Publicity reserves the right torequest up-to-date documents from the Users, even though they have passedidentity verification in the past.


User’s identification information will becollected, stored, shared and protected strictly in accordance with the PulaskiPublicity’s Privacy Policy and related regulations.


Once the User’s identity has been verified,Pulaski Publicity is able to remove itself from potential legal liability in asituation where its Services are used to conduct illegal activity.


1.2. Card verification


The Users who are intended to use paymentcards in connection with the Pulaski Publicity’s Services have to pass cardverification in accordance with instructions available on the PulaskiPublicity’s Site.


Compliance Officer


The Compliance Officer is the person, dulyauthorized by Pulaski Publicity, whose duty is to ensure the effectiveimplementation and enforcement of the AML/KYC Policy. It is the ComplianceOfficer’s responsibility to supervise all aspects of Pulaski Publicity’santi-money laundering and counter-terrorist financing, including but notlimited to:


Collecting Users’ identification information.b. Establishing and updating internal policies and procedures for thecompletion, review, submission and retention of all reports and recordsrequired under the applicable laws and regulations. c. Monitoring transactionsand investigating any significant deviations from normal activity. d.Implementing a records management system for appropriate storage and retrievalof documents, files, forms and logs. e. Updating risk assessment regularly. f.Providing law enforcement with information as required under the applicablelaws and regulations.


The Compliance Officer is entitled to interactwith law enforcement, which are involved in prevention of money laundering,terrorist financing and other illegal activity.


Monitoring Transactions


The Users are known not only by verifyingtheir identity (who they are) but, more importantly, by analysis of theirtransactional patterns (what they do). Therefore, Pulaski Publicity relies ondata analysis as a risk-assessment and suspicion detection tool. PulaskiPublicity performs a variety of compliance-related tasks, including capturingdata, filtering, record-keeping, investigation management, and reporting.System functionalities include:


1) Daily check of Users against recognized“black lists” (e.g. OFAC), aggregating transfers by multiple data points,placing Users on watch and service denial lists, opening cases forinvestigation where needed, sending internal communications and filling outstatutory reports, if applicable;


2) Case and document management.


With regard to the AML/KYC Policy, PulaskiPublicity will monitor all transactions and it reserves the right to:


ensure that transactions of suspicious natureare reported to the proper law enforcement through the Compliance Officer;

request the User to provide any additionalinformation and documents in case of suspicious transactions;

suspend or terminate User’s Account when PulaskiPublicity has reasonably suspicion that such User engaged in illegal activity.


The above list is not exhaustive and theCompliance Officer will monitor Users’ transactions on a day-to-day basis inorder to define whether such transactions are to be reported and treated assuspicious or are to be treated as bona fide.


Risk Assessment


Pulaski Publicity, in line with theinternational requirements, has adopted a risk-based approach to combatingmoney laundering and terrorist financing. By adopting a risk-based approach,Pulaski Publicity is able to ensure that measures to prevent or mitigate moneylaundering and terrorist financing are commensurate to the identified risks.This will allow resources to be allocated in the most efficient ways. The principleis that resources should be directed in accordance with priorities so that thegreatest risks receive the highest attention.


Enhanced Due Diligence Procedures forHigh-Risk Customers


Enhanced Due diligence is a KYC process thatprovides a greater level of scrutiny of potential business partnerships andhighlights risk that cannot be detected by Customer Due Diligence. Riskmanagement procedures often differentiate based on a customer’s risk profile.It starts by taking steps to ensure you know who you are dealing with,understanding their activities and assessing their risk of money laundering.Determining if a potential account requires enhanced due diligence (EDD)includes:


Location of the business

Occupation or nature of business

Purpose of the business transactions

Expected pattern of activity in terms oftransaction types, dollar volume, and frequency

Expected origination of payments and method ofpayment

Articles of incorporation, partnershipagreements and business certificates

Understanding of the customer’s customers

Identification of beneficial owners of anaccount or customer

Details of other personal and businessrelationships the customer maintains

Approximate salary or annual sales

AML policies and procedures in place

Third-party documentation

Local market reputation through review ofmedia sources

Some EDD practical steps include:


Obtaining additional identifying informationfrom a wider variety or more robust sources and using the information to informthe individual customer risk assessment.

Carrying out additional searches (e.g.,verifiable adverse media searches) to inform the individual customer riskassessment.

Commissioning an intelligence report on thecustomer or beneficial owner to understand better the risk that the customer orbeneficial owner may be involved in criminal activity.

Verifying the source of funds or wealthinvolved in the business relationship to be satisfied that they do notconstitute the proceeds from crime.

Seeking additional information from the customer about the purpose and intended nature of the business relationship.


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