Compliance

Anti-money laundering

In accordance with the requirements of Federal Law No. 115-FZ of August 7, 2001, "On Counteracting the Legalization (Laundering) of Criminally Obtained Proceeds and the Financing of Terrorism", as well as other applicable laws and regulations of the Russian Federation, Non-Banking Credit Organization (NBCO) ER Finance LLC implements a comprehensive system of measures aimed at preventing money laundering (AML), combating the financing of terrorism (CFT), and preventing the financing of the proliferation of weapons of mass destruction (CPF) (hereinafter referred to as AML/CFT/CPF).

NBCO ER Finance LLC has adopted and implemented its Internal AML/CFT/CPF Regulations, which establish procedures for preventing money laundering, terrorist financing, extremist financing, and the financing of the proliferation of weapons of mass destruction. In implementing these measures, the Company also follows the recommendations and international standards issued by the Financial Action Task Force (FATF).

To ensure an effective internal control system and compliance with AML/CFT/CPF requirements, ER Finance LLC has appointed a designated Compliance Officer responsible for overseeing the implementation and ongoing effectiveness of the Company's compliance program.

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 the following 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 accession to the CRS and the amendments introduced into the Tax Code of the Russian Federation (Federal Law No. 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 enabling it to determine their tax residency. This process is called “obtaining client confirmation.”

To insiders

In accordance with Federal Law No. 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 individuals included in the list of their inclusion and removal. Individuals included in the insider list are subject to the requirements, restrictions, and obligations established by Federal Law No. 224-FZ. Current legislation provides for both administrative and criminal liability for the unlawful use of insider information.