Compliance

Anti-money laundering

In accordance with the requirements of Federal Law Nr. 115-FZ dated August 7, 2001 "On counteracting the legalization (laundering) of proceeds from crime and financing of terrorism", as well as the applicable regulatory legal acts of the Russian Federation, Non-banking credit organization (NBCO) "ER Finance" LLC implements all prescribed measures aimed at counteracting the legalization (laundering) of proceeds from crime, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction (hereinafter — AML/CFT/FPWMD).

NBCO "ER Finance" LLC has approved and implements the "Internal Regulation Concerning the counteracting the legalization (laundering) of proceeds from crime, the financing of terrorism, extremist activities and the financing of the proliferation of weapons of mass destruction" (hereinafter — the Regulation). When implementing the set of measures aimed at AML/CFT/ FPWMD, the NBCO also takes into account the recommendations of the Financial Action Task Force (FATF).

In order to ensure the organization of internal control for AML/CFT/FPWMD and the implementation of the Regulation, the NBCO has appointed a special official — a compliance officer.

Economic sanctions

In the course of its activities, NBCO "ER Finance" LLC complies with the requirements of international and domestic sanctions legislation. The primary objective in this regard is to prevent the involvement of NBCO "ER Finance" LLC and its clients in transactions that violate sanction restrictions.

FATCA

NBCO “ER Finance” LLC was registered on the IRS FATCA website. The registration has been approved, and GIIN has been assigned: CSJLDN.99999.SL.643 (registered name – NBCO ER Finance LLC).

CRS

CRS (Common Reporting Standard) is the common reporting standard for the automatic exchange of tax information, developed by the OECD (Organization for Economic Co-operation and Development), introduced for the purpose of combating tax evasion and protecting tax systems. Russia confirmed its participation and joined the CRS in 2016.

In connection with Russia’s joining to the CRS and the amendments introduced into the Tax Code of the Russian Federation (Federal Law Nr. 340-FZ dated November 27, 2017 "On amending part one of the Tax Code of the Russian Federation in connection with the implementation of international automatic exchange of information and documentation among international groups of companies"), persons concluding an agreement with the NBCO for the provision of financial services, are required to provide the NBCO with information that allows them to establish their tax residency. This process is called "obtaining client confirmation".

To insiders

In accordance with Federal Law Nr. 224-FZ dated July 27, 2010 "On Combating Insider Information Misuse and Market Manipulation and on introducing amendments to certain legislative acts of the Russian Federation", NBCO "ER Finance" LLC maintains an insider list and notifies the individuals included in its insider list of their adding to and removal from such list. The insiders are subject to the requirements, restrictions and obligations set forth in Federal Law Nr. 224-FZ. The current legislation provides for both administrative and criminal liability for the unlawful use of the insider information.