“Anti- Money Laundering (AML) & Counter Terrorist Financing (FTF) Policy
Maverick Solution LLC
Last updated September, 2023
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“Introduction and Purpose
Money Laundering is a global issue that affects all jurisdictions to varying degrees. Failure to prevent Money Laundering allows criminals to benefit from their illicitly gained funds and may have a damaging impact on Maverick Solution LLC’s reputation.
The purpose of this policy is to ensure that Maverick Solution LLC complies with all applicable legal and regulatory anti-money laundering and counter-terrorist financing (“AML/CTF”) and enforcement requirements that we are subject to including those of Georgia, the U.S., the UK and other EU-wide AML/CTF obligations.
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1. Definitions
“(1) Money laundering – the crime provided in the Articles 186, 194, and 1941 of Criminal Code of Georgia:
(1.1) Purchase or sale of property obtained knowingly by illegal means;
(1.2) Legalization of illegal income (money laundering) – giving legal form to illicit and/or undocumented property (use, purchase, possession, conversion, transfer or other actions in connection with property) in order to conceal its illegal and/or undocumented origin or to assist another person in evading liability, as well as concealment or disguising of its genuine nature, source of origin, location, dislocation, movement, its title and/or of other rights related to it;
(1.3) Use, purchase, possession or sale of property acquired through the legalization of illegal income.
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(2) Terrorism financing – the crime provided in the Article 3311 of Criminal Code of Georgia (Collection or supply of financial resources or other assets knowing that they will or may be used in full or in part by a terrorist or a terrorist organization and/or for carrying out terrorist activities, or for the commission of terrorist crime, and/or services have been knowingly rendered to a terrorist or a terrorist organization, or a terrorist has been provided with a hiding place or shelter and/or resources or other material support have been provided to a terrorist or a terrorist organization).
“(3) Other criminal offences – that involves other criminal offences that are closely connected to money laundering and terrorist financing such as fraud, market abuse and anti-bribery and corruption. Fraud and corruption, as separate offences, are not dealt with in this policy. The policy does, however, apply to dealing with any proceeds of crime that arise from these activities.
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“(4) Beneficial Owner – means any natural person who ultimately owns or controls the customer and/or any natural person on whose behalf a transaction is prepared, executed or carried out.
In case of corporate entities, Beneficial Owner shall be any natural person who ultimately owns or controls a legal entity through direct or indirect ownership of a sufficient percentage of the shares or voting rights or an ownership interest in that entity, or controls by other means.
A shareholding of 25 per cent of the shares or an ownership interest of more than 25 per cent in the customer’s share capital, held by a natural person, shall be an indication of direct ownership by that natural person. A shareholding of 25 per cent of the shares or an ownership interest of more than 25 per cent in the customer’s share capital, held by a legal entity, which is controlled by natural person(s), or by several companies, which are controlled by the same natural person(s), shall be an indication of indirect ownership by that natural person.”
“2. Guiding Principles
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Maverick Solution LLC is committed to taking appropriate measures to mitigate the chances of it being used for purposes of money laundering or the financing of terrorism. To that effect:
(1) Maverick Solution LLC has adopted policies and procedures to identify, assess, monitor and manage money laundering and terrorism financing risks. Maverick Solution LLC’s policies and procedures are comprehensive and proportionate to the nature, scale and complexity of its activities;
(2) Maverick Solution LLC takes the measures necessary to ‘know its customers’ appropriately, both at the point at which the business relationship is established and on an ongoing basis thereafter. No new client or costumer will be accepted by Maverick Solution LLC until their identity has been satisfactorily verified in accordance with the procedures set forth in this policy. This should inсlude situations where Maverick Solution LLC refuses to enter into a business relationship or carry out the transaction contemplated by the customer where, despite these measures, Maverick Solution LLC has a doubt as to the real identity of the Beneficial Owner, and, where it cannot remove this doubt Maverick Solution LLC must refuse to onboard the customer or satisfy itself that applicable laws permit the implementation of reduced measures.
(3) Maverick Solution LLC takes all appropriate measures to identify and verify Beneficial Owner(s) of an entity in accordance with the Article 1 (4) of this Policy.
(4) Employee and Administrator responsible for the fulfillment of this Policy will be given appropriate training to make sure they understand how the law applies to them and to explain their roles and obligations in respect of anti-money laundering and counter terrorism financing.
(5) The importance of making reports of any suspicious activity is communicated to all relevant staff.
3. Application of Guiding Principles
“(1) In order to fulfil the standards set by the Guiding Principles, Maverick Solution:
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conducts appropriate training(s) for its rresponsible employee and Administrator in relation to money laundering and undertakes AML/CTF training for other members of the staff;
provides information/reports to its Board of Directors on the operation and effectiveness of the company’s AML/CTF systems and controls;
documents its risk management policies and risk profile in relation to Money Laundering, including documentation on its application of those policies;
differentiates between Client Due Diligence (“CDD”) requirements for high, medium and low risk relationships. It conducts appropriate risk-based CDD checks accordingly, including enhanced due diligence (“EDD”) for Politically Exposed Persons (“PEPs”), their families and known close associates and other high-risk relationships. The general categorisation is a guide for the risk assessment of client relationships. The assessment could be impacted by suspicion raised or the weighing of the considerations in APPENDIX 1: Client Relationships – Risk indicators by the AML reviewer.
Assessed low risk relationships will typically be:
relationships with individuals or entities regulated by a reputable regulator which is based in an assessed low risk jurisdiction for anti-money laundering. As well as no adverse findings after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators were revealed;
relationships with individuals or entities that are not regulated by a reputable regulator but is based in an assessed low risk jurisdiction for anti-money laundering. As well as no adverse findings after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators;
relationships with individuals or entities regulated by a reputable regulator but is not based in an assessed low risk jurisdiction for anti-money laundering. As well as no adverse findings after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators.
Assessed medium risk relationships will typically be:
relationships with individuals or entities that are not regulated by a reputable regulator and are not based in an assessed low risk jurisdiction for anti-money laundering. As well as the prevalence of no adverse findings after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators
relationships which may meet the categorization of a presumed low risk relationships described above but there are significantly adverse findings which have been recently resolved by the entity or findings requiring greater monitoring after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators.
High risk relationships will typically be relationships with individuals or entities that are:
based in the countries listed by the Financial Action Task Force (FAFT) as being NCCT (Non-Cooperative Countries and Territories) (the list of NCCTs can be found at www.fatf-gafi.org);
based in the countries listed by the National Bank President’s Order N240/04 of December 18, 2019;
listed on the Office of Foreign Assets Control (“OFAC”) as Specially Designated Nationals (“SDNs”) and Blocked Persons;
who are listed by the United Nations as listed in the UN Suppression of Terrorism List;
based in the countries listed by the European uniоn “EU” as high-risk third countries;
“are included by the European uniоn in the Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions (available at:https://data.europa.eu/data/datasets/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions?locale=en);
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“are included in the United Kingdom’s Sanctions List (available at: https://www.gov.uk/government/publications/the-uk-sanctions-list).
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Significantly adverse findings after assessing the considerations in APPENDIX 1: Client Relationships – Risk indicators
seeks to ascertain the source of wealth and funds of its clients and the nature of their activities and business. Maverick Solution LLC does not maintain relationships with correspondent bank accounts. Shell banks and other financial institutions, non-authorized Virtual Asset Service Providers (VASPs), from non-equivalent and non-FATF countries and territories are at particular risk. In particular, Maverick Solution LLC does not do business with shell banks, other financial institutions and non-authorized VASPs.
has adopted reasonable measures to ensure that procedures have been put in place for identification of new customers who may not be able for valid reasons to provide certain documentation to verify the identity of ultimate beneficial owners of customers otherwise produced by other clients in respect of their identity.
Basis of Identification and Verification
“(1) Maverick Solution LLC is obliged to identify and verify the client in the following cases:
a) when starting the business relationship;
b) signing the one-time contract. ”
“(2) For the purposes of natural person’s identification, Maverick Solution LLC I shall acquire the following data:
a) Name and surname;
b) Date of birth;
c) Personal number (if possible);
d) Number indicated on national ID and/or passport, issuance date, issuing country, issuing authority and validity date;
e) Gender;
f) Citizenship;
g) Place of birth – country (also, the City – if possible);
h) Registered address;
i) Factual address.
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“(3) For the purposes of natural person’s identification who is legitimately residing in Autonomous Republic of Abkhazia and Tskhinvali Region (Former South Ossetian Region), Maverick Solution LLC shall acquire the following data:
a) Name and surname;
b) Date of birth;
c) Personal number;
d) Neutral ID or neutral travel document number, issuance date, issuing country, issuing authority and validity date (if possible);
e) e) Gender;
f) Citizenship;
g) Place of birth – country (also, the City – if possible);
h) Address.
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“(3) If the client is an individual entrepreneur (natural person) and Maverick Solution LLC is entering into business relationship for entrepreneurial reasons, the latter is obliged to acquire the following data:
a) Name and surname;
b) Date of birth;
c) Personal number (if possible);
d) Number indicated on national ID and/or passport, issuance date, issuing country, issuing authority and validity date;
e) Gender;
f) Citizenship;
g) Place of birth – country (also, the City – if possible);
h) Legal address;
i) Registered address.
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(4) Maverick Solution LLC is obliged to acquire at least the following data for the purposes of client natural person’s identification: name and surname, personal number (if possible) or date of birth or all the data required under this Article in case the value of transaction or interrelated transactions exceeds 3000 GEL or its equivalent in foreign currency.
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5. Verification of Natural Person’s Identity”
“(1) Maverick Solution LLC verifies natural person’s identity on the basis of the following documents:
a) In case of the citizen of Georgia – passport of a Georgian citizen, ID or driving license, a certificate of the compatriot;
b) In case of residents in Autonomous Republic of Abkhazia and Tskhinvali Region (Former South Ossetian Region) – neutral ID card or neutral travel card. If the person acquired an identification number, his identity shall be verified in accordance with the electronic list provided by the Service Development Agency;
c) In case of foreign nationals – resident card issued by the Service Development Agency, temporary identification card issued by the Service Development Agency, passport and/or any other document issued in accordance with Georgian legislation or international treaties designated to be used for border crossing, or a certificate of the compatriot;
d) In case of stateless persons – resident card issued by the Service Development Agency, temporary identification card or temporary travel document or passport issued by the Service Development Agency.
e) In case of individual entrepreneur – documents listed in the subparagraphs from “a” – “d” and extract issued by the Register of Entrepreneurs and Non-Entrepreneurial (Non-Commercial) Legal Entities of the National Agency of Public Registry;
(f) In case of a natural person under 14 – documents listed in the subparagraphs from “a” – “d” and birth certificate. ”
(2) Verification of a natural person is not obligatory in cases of virtual asset exchange value of which does not exceed 1500 GEL.
Identification of Legal Entity
“(1) Maverick Solution LLC obtains the following documents for the purposes of a legal entity’s identification:
a) Name;
b) Registration date;
c) Legal address;
d) Identification number (if possible);
e) Registration number (if possible);
f) Legal form;
g) Factual address. ”
“(2) In addition to the documents listed in the Paragraph 1 of this Article, Maverick Solution LLC shall obtain information regarding person(s) having governing and representative authority:
a) in case of a natural person – at least, name and surname, personal number (if possible) or date of birth or number of a document verifying an identity/citizenship of a natural person or all the data listed in the Article 4 (2) of this Policy;
b) In case of a legal person – name and identification number or registration number (if possible). For the cases when no identification and registration number is provided, any of the data listed in the Subparagraphs “b” “c” “f” “g” shall be obtained. ”
(3) For the cases when the client is a branch of a legal entity, Maverick Solution LLC shall obtain information regarding person(s) having governing and representative authority within the corporate structure of the parent company (in accordance with the Paragraph 2 of this Article).
(4) For the cases when the client is an administrative organ, international organization (agency) or diplomatic representation (embassy), Maverick Solution LLC shall obtain the following data: name of the client, legal address and identification information of the person(s) having governing and representative authority (in accordance with the Paragraph 2 of this Article).
Verification of a Legal Entity
“(1) Maverick Solution LLC verifies client legal entities on the basis of the following documentation:
a) In case of a legal entity registered in Georgia – extract issued by the Register of Entrepreneurs and Non-Entrepreneurial (Non-Commercial) Legal Entities of the National Agency of Public Registry;
b) In case of a legal entity registered in another jurisdiction – extract from the relevant registry and/or any other registration document verifying the registration fact of a legal entity. ”
(2) Documents obtained for the purposes of verification of a legal entity shall inсlude identification information relevant for the date of verification and they must be dated (issuance date of a document). The documents obtained shall not be issued more than 12 moths before the date of verification, unless the verification involves direct access to the registry of legal entities.
“(3) For the cases when the documents obtained in the verification process in accordance with the Article 6 (1) Subparagraphs “a” – “f” and (2) Paragraph, Maverick Solution LLC is obliged to verify the data using trustable and independent source.
Trustable and independent source can be Register of Entrepreneurs and Non-Entrepreneurial (Non-Commercial) Legal Entities for the legal entities and its branches, and in case of foreign legal entities – the relevant register. ”
(4) For the cases when the client is a branch of a legal entity, it is obligatory to verify person (s) having governing and representative authority within the corporate structure of a parent company.
(5) Maverick Solution LLC shall verify the identification of Georgian administrative organ, international organization (agency), international financial institution and diplomatic representation (embassy) on the basis of publicly available other trustable source.
Know Your Client (KYC)
(1) Maverick Solution LLC uses Know Your Client (KYC) procedure for the purposes of obtaining information regarding the client(s) and its (their) verification.
(2) For the purposes of administering automatic checks within the Know Your Client (KYC) procedure, Maverick Solution LLC has a contractual relationship with Sum & Substance Ltd (registered in the United Kingdom; Registration Number: 09688671; Address: 30 St. Mary Axe, London, England, EC3 8BF; Data Protection Registration Number: ZA222205).
Enhanced Due Diligence (EDD) towards Politically Exposed People (PEPs)
(1) Maverick Solution LLC undertakes Enhanced Due Diligence (EDD) measures towards Politically Exposed People.
“(2) Politically Exposed Person shall be a natural person performing important public or political functions (except for low and medium rank officials), including:
a) a head of a state, a head of government, a member of government (minister), deputy minister, a head of a state institution;
b) a member of a legislative body (parliament);
c)a head of geopolitical association, or a member of the management body thereof;
d)a member of a Supreme Court, a Constitutional Court, or other court of the highest instance whose decisions are appealed in exceptional cases;
e) a general auditor, a deputy general auditor, a member of a Court of Auditors;
f) a member of a national (central) bank;
g) an ambassador, or a head of a diplomatic representation;
h) a chief officer of defense (military) forces;
i) a head of an enterprise operating with the participatory interest of a state, or a member of the management body thereof;
j) a head of an international organization, a deputy head of international organization, or a member of the management body thereof. ”
(2) “Prominent public function” depends on the nature of the position held, functions, and whether the function gives rise to the risk of large-scale abuse of position
(3) Maverick Solution LLC undertakes Enhanced Due Diligence (EDD) measures towards Politically Exposed People’s family members. Family members of PEPs shall be spouse/person who is equivalent to a spouse, sister, brother, parents, children/person who is legally adopted and their spouse(s)/ person who is equivalent to a spouse.
(4) Maverick Solution LLC undertakes the following measures – on the basis of the Administrators’ approval starts or continues professional relationship with Political Exposed Persons (PEPs), takes measures to identify the source of their wealth, money and virtual assets.
(5) Maverick Solution LLC undertakes the relevant measures included in this Policy to identify the beneficial owners and check whether client or its beneficiary is a Politically Exposed Person (PEP).
Risk-Based Approach
(1) On the basis of this Policy, Maverick Solution LLC undertakes risk-based approach and therefore, Client Due Diligence (CDD) measures are determined on a risk-sensitive basis by reference to customer type, type of business relationship, product type, transaction type and geographic risk factors. Enhanced CDD measures are required in any situation which presents a higher risk of money laundering or terrorist financing, including measures to verify the identity of ultimate beneficial owners of customers and to understand the ownership and control structure of customers which are legal persons, trusts or other legal arrangements. In addition, ongoing monitoring measures and approach must be determined on a risk-sensitive basis by reference to customer type, type of business relationship, product type transaction type and geographic risk factors.
(2) Simplified CDD procedures can only be used towards the low-risk relationship (Article 3 of this Policy).
(3) Enhanced Due Diligence (EDD) shall be used towards Political Exposed Persons (PEPs), as well as towards extraordinary/suspicious transactions. An extraordinary transaction shall be a complex, extraordinarily large transaction or an extraordinary set of transactions without a clear economic (commercial) or legal purpose.
(4) Maverick Solution LLC undertakes measures against the transactions involving virtual assets that are excessively large for an initiator and involves Enhanced Due Diligence (EDD) measures for further check.
“(5) In order to identify extraordinary/suspicious transactions, the following factors should be considered before entering into the relationship:
a) Responsible person(s) on AML must be sure as to the identity of all principals and ultimate controllers of any legal entity;
b) Nature of activities undertaken by a natural or legal person, their income/source of wealth shall not be excessively disproportionate to the transaction involving virtual assets;
c) Source of wealth/funds shall be identified;
d) Geographic location of an entity and citizenship of natural persons shall be verified whether they are located in a country on the non-cooperative countries and territories (list (“NCCT List”) maintained by FATF or list by the National Bank President’s Order N240/04 of December 18, 2019;
e) other unusual factors – secrecy, complex legal structures, inappropriate request related to virtual asset provision. ”
APPENDIX 1: Client Relationships – Risk indicators
“Higher Risk Indicators:
(1) Client/investor or beneficial owner, is established, registered, resident in or operating from (or, in the case of an individual, is a citizen of) a high risk country – high risk countries are those which are designated by:
The Financial Action Task Force (FAFT) as being NCCT (Non-Cooperative Countries and Territories) (the list of NCCTs can be found at www.fatf-gafi.org);
The National Bank President’s Order N240/04 of December 18, 2019 as high-risk jurisdictions;
The European uniоn as high-risk third countries;
The Office of Foreign Assets Control (“OFAC”) (U.S.) as Specially Designated Nationals (“SDNs”) and Blocked Persons;
The United Nations as listed in the UN Suppression of Terrorism List;
The European uniоn in the Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions (available at:
https://data.europa.eu/data/datasets/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions?locale=en);
The United Kingdom’s Sanctions List (available at:
https://www.gov.uk/government/publications/the-uk-sanctions-list);
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“(2) Client/investor (or beneficial owner of client/investor), including their immediate family members or close associates, is a PEP, foreign or domestic (i.e. a person who within the last year has held a prominent public function);
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(3) Client/investor is unwilling to provide information in relation to its identity or that of its beneficial owners(s) and/or is unduly concerned in relation to maintenance of secrecy.
(4) Client/investor requests transactions that might favor anonymity;
(5) Client/investor requests investment through unusual or complex structure where the reason for request is unclear;
(6) Transaction is suspicious based on the provisions included in the Article 10 of this Policy.
(7) Client/Investor used false identification documentation and/or operates multiple accounts and/or uses third party accounts for transactions and/or uses variation when spelling names/addresses;
(8) Client/Investor uses an agent without a good reason and/or refuses to provide additional information for verification and/or uses unusual domain addresses and the information regarding legal entity cannot be identified or verified;
(9) Client/Investor operates multiple accounts from different countries without actual link between them;
(10) Client/Investor executes the transaction that is obviously under-estimated or overestimated or inconsistent.
(11) Client/Investor provides false documentation to Maverick Solution LLC.