CONDICIONES GENERALES DE USO

El Código de Buena Conducta de para los usuarios

AGREEMENT BETWEEN SHOSHORO N.V. AND THE INDEPENDENT PERFORMER (the Performer Agreement)

(20 November 2019)

Terms and Conditions Applying between SNV and the Performer (hereafter: Performer)
The following Performer Agreement and all terms and conditions shall apply to the legal relationship between SNV and the Performer.

This Performer Agreement describes the general terms & conditions that apply when a Performer uses the services provided by SNV, namely:
A. General Platform Services
B. SNV Payment Service (Billing)

1. General

1.1 This Performer Agreement replaces all previous agreements between the Performer and SNV and the available Payment Service (Billing) and General Platform Services" offered by SNV.
1.2 If the Performer has questions about this Performer Agreement, the Performer can consult the FAQ page (Frequently Asked Questions) or contact SNV via the contact form on the SNV Platform.
1.3 SNV has the right to make changes to the Performer Agreement. SNV will notify the Performer of such changes by means of placing the new, amended Performer Agreement on the SNV Platform, by means of an e-mail to the registered Performer upon request, or by other means. Changes will take effect 14 days after being announced, or at another time if this is stipulated in the notification. If the Performer is unable to agree with the changes the Performer Agreement will terminate.
1.4 This Performer Agreement is drawn up in the English language. In the event of a conflict between the English version and a version in another language the English version will prevail.
1.5 This form will be countersigned by SNV and consultable at any time on the Performer account.

2. Definitions

2.1 Entertainment Webcam Service: a service offered and sold by the Performer.
2.2 E-Wallet: virtual credit balance registered by SNV upon receipt of funds from the User. The User's E-Wallet is stored in the SNV computer system. The E-Wallet is not an account but a virtual balance.
2.3 Financing Transaction: the transaction in which the User deposits credits into his/her virtual balance (E-Wallet).
2.4 General Platform Services: the services SNV provides to the Performer for the use of the SNV Platform in return for payment.
2.5 Payment Day: the 1st or 16th day of each calendar month. If this day falls on a Saturday, Sunday or public holiday, the Payment Day will be postponed to the next following days.
2.6 Payment Instruction: the authorisation the User gives SNV to deduct the payment from the virtual credit balance in the User's E-Wallet for the Entertainment Webcam Services purchased from the Performer; these credits are automatically and instantly credited to the Performer Payment Account.
2.9 Payment Transaction: the transaction in which SNV transfers the credits held in the Performer's Payment Account into the bank account of the Performer.
2.10 Policy Rules: documents prepared by SNV and published on the SNV Platform containing mandatory or non-mandatory rules which apply to the relationship between SNV and the Studio Performer as a result of the Form including but not limited to Privacy/ GDPR rules, Code of Conduct, KYC rules and AML rules.
2.11 Reservation Requirement: the amount that SNV reserves temporarily in accordance with the Performer Agreement to cover possible payment cancellations by Users.
2.12 SNV refers to , registered with the Chamber of Commerce under number 122760, with its offices at E-Commerce Park Vredenberg, unit 23, Willemstad, Curaçao and to the companies and Partners affiliated with
2.13 SNV Payment Service: crediting the Performer Payment Account, upon the deduction of a virtual credit balance held by the User (E-Wallet), for payment of Entertainment Webcam Services the Performer has sold to the User.
2.14 SNV Platform: the technical platform exploited by SNV that enables the Performer to provide and sell Entertainment Webcam Services anonymously and enables the User to purchase Entertainment Webcam Services anonymously.
2.15 Performer: the party who offers and sells his Webcam Entertainment Services to the Users via the SNV Platform and either operates as an independent professional or as a micro company in his country of residence.
2.16 Performer Agreement: these general terms and conditions as agreed between the Performer and SNV also referred to as "you" or "Model".
2.17 Perform er Account: the Performer's personal registration on the SNV technical platform containing the personal information of the Performer (Performer's Profile and the Performer's Name).
2.18 Performer Fees: the fees SNV charges to the Performer for providing the General Platform Service and the SNV Payment Service.
2.19 Performer's Name: the name under which the Performer is registered. Also the name that, in combination with the personal password, gives access to the Performer's Account.
2.20 Performer Payment Account: the Performer's current account with SNV, to which SNV credits payments made by Users for the purchase of the Webcam Entertainment Services provided and sold by the Performer and to which SNV debits amounts owed to SNV by the Performer.
2.21 Performer's Profile: the full personal and physical description of the Performer.
2.22 Third Party: any party except the Performer and SNV.
2.23 Transaction Fees: the costs associated with the Payment Transaction.
2.24 User: a person who purchases entertainment services from the Performer via a Website connected to the technical platform of SNV and who may or may not use the SNV Payment Service (E-Wallet).
2.25 User Account: the User's personal registration on the SNV technical platform.
2.26 Website: a website linked to the technical platform of SNV.
2.27 Micro Company: an enterprise which meets two of the following three criteria and do not fail to do so for at least 10 years (1) fewer than 10 employees, (2) balance sheet total below 2 million euro and turnover below 2 million euro. (definition European Union).

3. Registration of the Performer

3.1 The Performer must be a person who is legally competent and authorised to sign binding agreements and must be at least 18. If the legislation in the country of the Performer differs from this rule the Performer Manager/Owner must be at least 21. For this purpose the Performer will supply a copy of a valid ID of the Performer together with his photograph.
3.2 A person whose (Studio) Performer Account has been temporarily or permanently suspended, cannot register a Performer.
3.4 The Performer is obliged to make a Performer Account by completing and sending the applicable on-line registration form and upload all forms as requested during the registration process.
3.5 The moment SNV has received and approved the documents, SNV shall send the Performer an e-mail to confirm the registration, a link and a password to access the Performer Account.
3.6 After approval the Performer will have access to the countersigned Performer Agreement on his Performer Account and will be able to offer and sell Webcam Entertainment Services (Effective Date).
3.7 The Performer shall be under the obligation to supply current, correct, complete and truthful data in respect of himself. The Performer shall furthermore be under the obligation to immediately inform SNV of any changes in said data (such as Address, Banking Information, etc.).
3.8 There is no charge for registering as a Performer.
3.9 In the event of non-compliance with this article SNV shall be entitled to dissolve the Performer Agreement with immediate effect or to suspend the Performer Agreement for an (in)definite period of time.

4. Password and Performer’s Name

4.1 The Performer is responsible for all actions (including but not limited to safeguarding the secrecy) involving the Performer’s Name and his password.
4.2 The Performer must observe all the appropriate security measures to protect his password. The Performer is not allowed to reveal such password to Third Parties.
4.3 Neither is the Performer allowed to permit Third Parties to use the Performer’s Name and his password either directly or indirectly.
4.4 The password and Performer’s Name given to the Performer is for that person ONLY.
4.5 The Performer indemnifies and holds SNV harmless from any loss of his password and/or Performer’s Name, including but not limited to; actual, total, capital or consequential loss, for reason of the Performer not safeguarding the secrecy of the password to their account. In this case, the Performer shall be liable for the costs incurred and the damage sustained by SNV. SNV shall never be liable to the Performer for any damage resulting from loss, theft, publication or misuse of the password of the Performer.
4.6 In the event there is any suspicion that the password and/or the Performer’s Name of the Performer are misused, the Performer shall immediately notify SNV thereof.

5. SNV is a technical platform only

5.1 SNV acts exclusively as a technical platform that enables the Performer to provide and sell Entertainment Webcam Services anonymously and enables the User to purchase Entertainment Webcam Services anonymously.
5.2 SNV does not check, monitor or validate the Entertainment Webcam Services provided and sold by the Performer and SNV is in no way involved in the Entertainment Webcam Services provided and sold by the Performer.
5.3 SNV has no control over the quality, safety or legality of the Entertainment Webcam Services offered and sold by the Performer, the Performer’s competence to offer and sell the Entertainment Webcam Services and the User’s competence to purchase the Entertainment Webcam Services.
5.4 SNV does not guarantee the Performer that the User will pay for the Entertainment Webcam Services purchased by the User from the Performer.
5.5 The provision and sale of the Entertainment Webcam Services by the Performer to the Users and the purchase of the Entertainment Webcam Services by the Users only constitute an agreement between the Performer and the Users. SNV is not a party to this sale.
5.6 The Performer agrees and acknowledges that SNV is not a party to and is not responsible for any dispute between the User and the Performer.

6. No representation

6.1 SNV on the one hand and the Performer on the other are independent professional parties; each party acts only in its own name and on its own behalf.
6.2 It is not the purpose of this Performer Agreement to establish an agency, mandate ship, partnership, joint venture or any other form of collaboration, an employer-employee relationship or a franchisor-franchisee relationship. The Performer Agreement consequently does not create any of the above.

7. Provision of Entertainment Webcam Services

7.1 The Performer is offering and selling the Entertainment Webcam Services to its customers which also means that the Performer has to comply with the applicable VAT rules in this respect as following from the decision of the European Court of Justice (ECLI:EU:C:2019:388).
7.2 SNV does not determine the price of the offered Entertainment Webcam Services.

8. Services provided by SNV to the Performer

8.1 SNV will provide the Performer:
I. General Platform Services
II. SNV Payment Service (Billing)
8.2 The amount of the Payment Transaction is based on 50% (or another percentage agreed otherwise) of the turnover of the Performer. The remaining amounts are retained by SNV to cover the payment of the invoices of SNV due by the Performer for the General Platform Services and the SNV Payment Services. In case part of the General Platform Services are provided by an Affiliate under a contract in this respect with AC Webconnecting NV, the part of the Performer Fees related to those services, will be retained for the account of AC Webconnecting NV.
8.3 The Performer can download at any time from his Performer Account the invoices which have been paid by retaining amounts from the Performer Fees as set out above.
8.4 Transaction Fees may apply depending on the chosen payment method as laid down in the Performer Account.
8.5 SNV is entitled to change General Platform Fees. Changes take effect 14 days after the change has been announced on the SNV Website, unless stipulated otherwise. If, in the 14 days after this change, the Performer notifies SNV that he/she does not accept the changes in question the Performer Agreement and the right to use the SNV paid services will terminate immediately upon receipt of this notification.

9. SNV Payment Service

9.1 The Performer is obliged to provide complete, up-to-date and correct registration information and information about the Performer Account and to update this information on a regular basis to keep it current and correct.
9.2 If a Financing Transaction is reversed for whatever reason (charge back from a User) SNV is entitled to recover such charge back from the Performer by debiting the previously credited amount back from the Performer's Payment Account.
9.3 SNV will carry out the Payment Transaction if the amount of the Payment Transaction entirely covers the costs SNV will incur in respect of the chosen payment method.
9.4 SNV has a Reservation Requirement of 5 percent of Performer’s turnover. The Reservation Requirement is a temporary reserve (180 days) to cover potential payment cancellations (charge backs) by the User.
9.5 SNV can suspend a Payment Transaction if SNV, at its own discretion, suspects that the Transaction: is based on a factual error; is fraudulent or is made using a fraudulent or invalid method of payment.
9.6 SNV will notify the Performer about the suspension of any Payment Transaction.
9.7 SNV is entitled to deduct all payment obligations that SNV may accrue under this Performer Agreement from the Performer's Payment Account, in addition to all other rights and legal means available to SNV pursuant to this Performer Agreement.
9.8 SNV is not liable to the Performer or third parties for any loss suffered by the Performer as a result of imposed transaction limits, Reservation Requirements, payment cancellations or other refund demands.
9.9 The Performer agrees that:
a. the Performer's Payment Account may not be a deposit account;
b. SNV is not required to pay the Performer interest on any balance in the Performer's Payment Account.
9.10 Any dispute with respect to the SNV Payment Service must, in the first instance, be reported to the SNV online support team.
9.11 The Performer is not obliged to use the SNV Payment Service in providing and selling the Entertainment Webcam Services.
9.12 SNV is entitled to change its Billing Fees. Changes take effect 14 days after the change has been announced on the SNV Website, unless stipulated otherwise. If, in the 14 days after this change, the Performer notifies SNV that he/she does not accept the changes in question the Performer Agreement and the right to use the SNV paid services will terminate immediately upon receipt of this notification.

10. Guarantees

10.1 Each party declares and guarantees that he/she is legally competent and authorised to sign this Performer Agreement.
10.2 The Performer guarantees SNV that:
a. the Performer and the Performer will comply with:
• all the laws, regulations and bylaws that apply to the provision and sale of /his/her Entertainment Webcam Services;
• all the laws, regulations and bylaws related to the Performer’s use of the General Platform Services and/or SNV Payment Service
• (the rules resulting from) the Performer Agreement.;
• the national legislation of the country in which the Performer is located.
b. the Performer will not attempt to initiate or receive a Payment Transaction that is illegal or fraudulent or that conflicts with the applicable legislation and regulations;
c. the Performer will pay all taxes, levies and commissions it is due in connection with the use of the SNV services and/or the SNV Platform and/or the Website as well as in connection with the Webcam Entertainment Services sold by the Performer to the Users.
10.3 The Performer indemnifies and/or shall be liable for any damage sustained by SNV as a result of non-compliance with the stipulations of section 10.2 of the present article. The Performer cannot exculpate itself towards SNV by stating that the damage arose as a result of a violation by the Performer. The Performer shall be liable for its or its Performer's actions at all times.
10.4 SNV guarantees the Performer that she will provide the General Platform Services and the SNV Payment Service with reasonable care and professionalism.
10.5 SNV does not guarantee that the General Platform Services and the SNV Payment Service will meet all of the Performer’s requirements and will function uninterruptedly, be virus-free, safe or error-free.

11 Announcement and notification

11.1 Declarations, notifications and other announcements from SNV to the Performer can be made by post, e-mail, via publications on the SNV Platform or by any other reasonable method.

12. Obligations of the Performer

12.1 The Performer – and not SNV -is responsible and liable for the information placed in the Performer Account as well as for the Performer's Profile and the Performer’s name.
12.2 The information as mentioned in article 12.1 and any actions on the part of the Performer and/or the Performer cannot:
a. be incorrect, inaccurate or misleading;
b. be insulting, threatening, damaging or defamatory;
c. infringe copyrights, privacy or other rights;
d. break the law or violate any other regulations;
e. breach public order and/or public morals;
f. be obscene or inappropriate or contain child pornography;
g. create liability for SNV or cause the (full or partial) loss of its services;
h. cause the SNV technical platform to suffer interruptions or damage, function less efficiently or be influenced in such a way that its effectiveness or functionality is in any way diminished.
12.3 The Performer gives SNV a non-exclusive, worldwide, uninterrupted, irrevocable, royalty-free and transferable (via several third parties) license to exercise the copyrights, trademarks, publicity and database rights with respect to the Information (always including pictures, videos and online images) the Performer has placed on known and as of yet unknown media, to the extent that this is necessary to provide its General Platform Service to the Performer.
12.5 Any claim that a Performer may have, by a right in law or statute, by the Performer's failure of execution under this Performer Agreement, shall be safeguarded against SNV and the Performer shall indemnify SNV against all costs of such claims.
12.6 The Performer is not allowed to provide any personal information (including name, address, telephone number, e-mail address, social media accounts, etc.) of the Performers to Third Parties or to attempt to obtain such information from Third Parties in any way.

13. Fraud, money laundering and terrorism financing

13.1 Without prejudice to any other legal remedy, SNV can suspend or terminate the Performer's Account if actions on the part of the Performer cause SNV to reasonably suspect or give the impression that there is any form of involvement or association with fraudulent activities (fraud, money laundering and terrorism financing) on the SNV technical platform.
13.2 If the Performer commit(s) fraud or deliberately or as a result of gross negligence fails to comply with the stipulations of the Performer Agreement with respect to the Performer's Account, the Performer is liable for all loss suffered in relation to the unlawful transactions.

14. Violation of the Performer Agreement

14.1 SNV has the right to send the Performer an immediate warning, suspend or terminate the Performer and/or Performer's Account temporarily or indefinitely and refuse to provide services to the Performer if:
a. the Performer and/or the Performer violate(s) the Performer Agreement or the documents that form an integral part of the Performer Agreement.
b. it proves impossible for SNV to verify the correctness of the information provided by the Performer.
c. SNV feels that by his/her actions the Performer will or may cause damage to SNV.

15. Limitation of liability SNV

15.1 SNV can never be held liable for any direct or indirect damage or (consequential) loss, including but not limited to: any loss or falsification of data; loss of profits (suffered directly or indirectly);loss of turnover; loss of goodwill or reputation; loss of opportunity;
or for indirect, incidental, additional or any other damage, irrespective of whether the loss or damage is attributable to any change SNV has made to the SNV Platform or the SNV Payment Service, or due to a permanent or temporary interruption in the SNV Platform or SNV Payment Service, and irrespective of any negligence or other cause.
15.2 SNV's liability to the Performer – irrespective of the circumstances – is in any case limited to the total of the amounts the Performer has received from SNV in the 3 months preceding the legal action that gives rise to the liability, with a maximum of 100 Euros.

16. Account not Assignable

16.1 The Performer Account is non assignable, shall be strictly personal and must not be transferred to or used by any Third Party.
16.2 The Performer Account can only be used by the Performer for whom such account is created.
16.3 Creating a Performer Account or a Performer Account for a third party shall be prohibited.

17. Other

17.1 The Performer agrees that SNV can freely and by operation of law transfer the rights and obligations arising from this Performer Agreement and from all the documents that apply for reference purposes in the event of a merger, division, takeover or other restructuring.
17.2 If SNV fails to act in respect of a violation of this Performer Agreement by the Performer or by others, SNV does not automatically waive the right to act in respect of later or similar violations.
17.3 If SNV does not exercise or enforce a legal right or legal remedy referred to in this Performer Agreement (or to which SNV is entitled in accordance with the applicable law) this cannot be considered a waiver of the rights of SNV. Neither can it be considered a waiver of the right to act in respect of later or similar violations. SNV can and may always use its rights or legal remedies
17.4 This Performer Agreement, accompanied by the documents and Policy Rules in relation to the SNV Platform as published on the Platform, included, constitute the entire agreement between the Performer and SNV.

18. Applicable law

18.1 Curaçao law applies to this Performer Agreement.
18.2 Any disputes that arise or may arise between the Performer and SNV as a result of this Performer Agreement or subsequent agreements or other actions in relation to this Performer Agreement will be settled by the competent courts in Curaçao.

19. Termination of the Performer Agreement

19.1 The Performer Agreement will remain in place until such time as it is cancelled by the Performer or by SNV, as outlined below. If the Performer Agreement is cancelled, this means that the Performer Account and the Performer Accounts will be closed by SNV.
19.2 If the Performer wishes to terminate this Performer Agreement with SNV the Performer can do so at any time and free of charge by closing the Performer Account and the Performer's Account(s).
19.3 SNV can terminate the Performer Agreement with the Performer at any time without prior notice if: the Performer has violated the Performer Agreement or SNV is legally obliged to do so.
19.4 The termination of this Performer Agreement does not affect the legal rights, obligations and responsibilities the Performer and SNV have used, that have applied to the relationship between the Performer and SNV, or that arose in the period that the Performer Agreement was in effect or for which it is stipulated that they remain valid for an indefinite period such as but not limited to "Definitions", "No representation", "Guarantees", "Obligations of the Performer", "Fraud, money laundering and terrorism financing", "Announcements and notification", "Applicable law" and "Other".
19.5 Upon termination of this Performer Agreement or any other termination of the use of the SNV Payment Service by the Performer, the Performer remains responsible for all cancellations and recovery costs (charge backs).

I declare that I am independent professional or micro company in my country.

La declaración de confidencialidad de

25 de mayo de 2018

La protección de datos es particularmente prioritaria en nuestra empresa. En cuanto al procesamiento de datos, cumplimos estrictamente con los requisitos de la legislación de protección de datos aplicable, incluido el Reglamento General de Protección de Datos de la UE (GDPR). Lo significa que:

limitamos nuestra colecta de datos personales solamente a los datos personales necesarios para fines legítimos;
**especificamos claramente nuestros objetivos ** antes de procesar los datos personales, en conformidad con la presente Declaración de confidencialidad.
en primer lugar solicitamos el permiso explícito para tratar tus datos personales en los casos en que se requiera tu autorización;
*tomamos las medidas de seguridad apropiadas para proteger tus datos personales y exigimos lo mismo a las partes que tratan tus datos personales en nuestro nombre;
respetamos* tu derecho a consultar, corregir o eliminar **los datos personales que nosotros poseemos.

es la entidad responsable del procesamiento de todos los datos. En la presente Declaración de confidencialidad, nosotros explicamos cuales son los datos personales que colectamos y para qué fines. Te recomendamos que lo leas atentamente.

Inscripción

Algunas funcionalidades de nuestro sitio requieren que te inscribas previamente. Deberás proporcionar información sobre ti y elegir un nombre de usuario y una contraseña para la cuenta que vamos a crear para ti.
Para este fin, utilizamos tu nombre, dirección, número de teléfono, dirección de facturación, dirección de correo electrónico, detalles de pago y nombre de usuario. Necesitamos estos datos en razón del acuerdo que existe entre nosotros. Nosotros almacenamos esta información hasta que cierres tu cuenta.
Conservamos esta información para que no tengas que volver a ingresarla cada vez que visites nuestro sitio, para poder intercambiar mensajes contigo en el marco de la ejecución del acuerdo y, además, para poder brindarte la lista de servicios que has comprado en nuestra plataforma.

Carga de la billetera electrónica (E-Wallet)

A través de m.camlis.com, puedes cargar créditos en tu Ewallet para adquirir los servicios ofrecidos por las otras partes. Esto requiere cierta información personal que compartimos con los proveedores de pago para facilitar la carga de las billeteras electrónicas (E-Wallet).

Tus datos personales que nosotros utilizamos son tu nombre y dirección, dirección de facturación, dirección de correo electrónico y detalles de pago. Necesitamos estos datos en razón del acuerdo que existe entre nosotros. Almacenamos esta información durante el período de conservación legal impuesto por la administración fiscal.

Promoción

Nosotros promovemos nuestros nuevos productos y nuevos servicios a través de nuestro boletín informativo. Puedes negarte en todo momento a recibir esta comunicación promocional. Cada e-mail enviado contiene un enlace de cancelación.

El consentimiento para la colecta de datos personales, que has dado para recibir el boletín informativo, puede ser revocado en todo momento. Para ejercer tu derecho a revocar tu consentimiento, siempre encontrarás un enlace dedicado en cada boletín. También es posible darte de baja del boletín informativo en cualquier momento directamente en la plataforma.

Publicidades

Nuestro sitio web muestra publicidades genéricas. Nosotros no colectamos ningún dato personal para este propósito.

Cookies

El sitio usa cookies Las cookies son archivos de texto almacenados en un sistema informático a través de un navegador de Internet. Las cookies son necesarias para permitirnos mejorar el funcionamiento de nuestro sitio web y para reconocerte durante tus visitas. De esta manera, no tienes que iniciar sesión cada vez y nosotros nos recordamos de tus configuraciones y tus preferencias. No compartimos las cookies con terceros y no orientamos la publicidad basándonos en las cookies.

Puedes desactivar las cookies a través de la configuración de tu navegador, pero esto puede impedir la utilización de algunas funcionalidades del sitio.

Uso compartido de datos personales con terceros

A excepción de las partes mencionadas anteriormente, no compartimos tus datos personales con otras compañías u organizaciones, a menos que así lo exija la ley.

Estadísticas

Hacemos estadísticas sobre el uso del sitio, lo que nos lleva a utilizar datos personales. Utilizamos estas estadísticas para mejorar la presentación y el funcionamiento de nuestro sitio web y accedemos a los datos personales solamente en caso de estricta necesidad de tal efecto.

Seguridad

Tomamos las medidas de seguridad adecuadas para limitar cualquier uso indebido o acceso no autorizado a los datos personales.

Modificación de nuestra Declaración de Confidencialidad

Nos reservamos el derecho de cambiar nuestra Declaración de Confidencialidad. Te recomendamos que la consultes regularmente para mantenerte informada/o de cualquier cambio.

Ver y modificar tus datos

Puedes ponerte en contacto con nosotros si tienes alguna pregunta sobre nuestra Declaración de Confidencialidad o si deseas ver, modificar o eliminar tus datos personales.

Tus derechos son detallados a continuación:

• Ser informado de los datos personales que poseemos y del uso que hacemos de ellos;
• Controlar los datos personales que son colectados y almacenados;
• Modificar los datos personales incorrectos;
• Solicitar la eliminación de datos personales obsoletos;
• Revocar tu consentimiento;
• Oponerse a ciertos usos.

Ten en cuenta que siempre deberás iniciar sesión para poder ejercer tus derechos de ver / modificar / eliminar tus datos personales, a fin de garantizar que no modifiquemos ni borremos datos de la persona incorrecta.

Reclamos

Si consideras que no te estamos permitiendo ejercer tus derechos de forma adecuada, puedes presentar un reclamo ante la autoridad nacional de protección de datos si resides en la Unión Europea. * Por ejemplo, en España, la Agencia Española de Protección de Datos (AEPD)*.

Información de contacto

Teléfono:
Correo electrónico:
Sitio web: m.camlis.com

, a Curaçao Corporation, does hereby voluntarily state that all performers appearing on this web site and issuing their respective sexually explicit images, were at least 18 (eighteen) years-of-age with governmental picture identity records on file in compliance with the spirit of 18 U.S.C. §2257.

Documentation as aforesaid is retained and only disclosed in conformance with Curaçao and EU Privacy Statutes.

Please direct any inquiries to:
Custodian of Records

ANTI-MONEY LAUNDERING/ KYC POLICIES, CONTROLS AND PROCEDURES

DOCUMENT UPDATED THE 3 TH DECEMBER 2019

, as a member of the AC Group, will also act in accordance with this Policy Rule as laid down in this Group Policy AML/KYC statement.
It is the policy of AC Group that all members of staff at all levels shall actively participate in preventing the services of AC Group from being exploited by criminals and terrorists for money laundering purposes. This participation has as its objectives:

• ensuring AC Group’s compliance with all applicable laws, statutory instruments of regulation, and requirements of AC Group’s supervisory authority
• protecting AC Group and all its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements
• preserving the good name of AC Group against the risk of reputation damage presented by implication in money laundering and terrorist financing activities
• making a positive contribution to the fight against crime and terrorism.

To achieve these objectives, it is the policy of AC Group that:

• every member of staff shall meet their personal obligations as appropriate to their role and position in AC Group
• neither commercial considerations nor a sense of loyalty to Platform Users shall be permitted to take precedence over AC Group’s anti-money laundering commitment
• AC Group shall appoint the sole practitioner to be responsible for anti-money laundering compliance (the responsible AC Officer). AC Group shall notify the supervisory authority (if applicable) and supply the name of the responsible director
• AC Group shall appoint a Money Laundering Reporting Officer (MLRO). AC Group shall appoint a deputy to cover in the absence of the MLRO. The MLRO and deputy shall be afforded every assistance and cooperation by all members of staff in carrying out the duties of their appointments
• AC Group shall carry out a business-wide assessment of the risks of money laundering and terrorist financing to which AC Group is subject and design and implement appropriate controls to mitigate and manage effectively the risks identified
• AC Group shall establish and maintain documented, proportionate policies and procedures, including controls, which outline the positive actions to be taken by staff to prevent money laundering and terrorist financing in the course of their work. The MLRO shall keep these under review to ensure their continuing appropriateness.

POLICY AND PROCEDURE FOR THE ASSESSMENT OF MONEY LAUNDERING RISK

POLICY

It is the policy of AC Group to identify and assess the money laundering and terrorist financing risks represented by the business we conduct so that we can mitigate that risk by applying appropriate levels of persons and companies using the platform as exploited by (the Platform Users). The Platform Users are the so-called Service Providers that is the Studio and the Performer with which/whom has concluded the Studio Agreement respectively the Performer Agreement. Performer is also referred to as “Model”. These Service Providers offer and sell their services to their customers (Users) on the SNV Platform.

CONTROLS AND PROCEDURES

1. AC Group shall assess the money laundering risk represented by the Platform Users and the business conducted according to three levels:
   • the range normally dealt with by AC Group, requiring AC Group’s normal level of client due diligence
   • an exceptionally high level of risk requiring an enhanced level of client due diligence
   • a negligible level of risk requiring only simplified due diligence.
2. AC Group shall identify and maintain lists of risk factors (including those required by the Regulations) relating to the Platform Users, products or services, transactions, delivery channels and geographic areas of operation.
3. AC Group shall assess the level of risk associated with these factors by analysing indicators including:
   • characteristics of the Platform User (individual or corporate, status, location, occupation)
   • the purpose of accounts or engagements, levels of assets and transactions
   • regularity or duration of business relationships.
4. AC Group shall update the risk assessment annually to ensure new and emerging risks are addressed, and new information supplied by our supervisory authority is reflected.
5. AC Group shall keep an up-to-date written record of all steps taken and shall provide the risk assessment and the information on which it was based.
6. The money laundering or terrorist financing risk represented by each Platform User will be assessed:
   • during the new Platform User acceptance process (KYC), before any work is undertaken.
   • whenever AC Group’s process of ongoing monitoring indicates that a change in the business or operating environment of an established Platform User may represent a change in money laundering risk.
7. The risk assessment in relation to a Platform User shall be carried out by the responsible AC officer who will determine appropriate due diligence measures in respect of each Platform User based on:
   
   • AC Group’s business-wide risk assessment
   • assessment of the level of risk arising in any particular case.
8. A record must be made of the assessment of individual Platform User relationships, confirming that AC Group’s business-wide risk assessment has been taken into account, and any other relevant factors considered.

POLICY AND PROCEDURE FOR THE VERIFICATION OF IDENTITY OF THE PLATFORM USERS (KYC)

POLICY

It is the policy of AC Group to verify the identity of all Platform Users, ensuring that procedures reflect Platform User risk characteristics. When opening an account with the AC Group all Platform Users will be verified on the basis of the following procedures.

A. CONTROLS AND PROCEDURES FOR THE USE OF THE (SNV) PLATFORM

Platform Users who offer and sell their services on the SNV Platform – Performers and Studio’s – acting in the form of a corporate entity need to provide the following information:

• Company Name
• Official Registration number
• Social form
• Country of headquarters
• Address of the headquarters
• If applicable, intracommunity VAT number
• Contact mail address
• Phone number
• All information about the beneficial owners.

The responsible AC Officer will check that such Platform User is appropriately incorporated (if applicable) and registered, and take the necessary steps to determine who are the principal beneficial owners, and the people with significant control, and their identity will be verified according to this procedure.

B. Platform Users who offer and sell their services on the SNV Platform – Performers and Studio’s – not acting in the form of a corporate entity need to provide the following information:

• Name or identification of the non-individual Studio/Performer
• Country of implantation
• Address
• Phone number and contact mail address
  
• A waver stating his obligations of any taxes due and statement that he can act as a non legal entity in his country (micro-entreprises).

Verification of identity

1. The member of staff conducting verification of identity will complete the process by checking that the Studio/Performer is not the subject of sanctions or other statutory measures, using the screening methods set out by the MLRO. (Blacklist international terrorist, tel sms verification).
2. For Studio/Performers, identity checks will be conducted by examination of:
   • one document containing a photograph confirming the Studio Manager/ Performer’s name, such as a valid passport
   • photo with the given identity document next to face
   • one document confirming the Studio Manager/Performer’s address, such as a utility bill (less than 3 months old and no mobile telephone bill). This document is required even if the document confirming name also has the address AC Group’s MLRO will maintain a list of acceptable documents or information obtained from a reliable source which is independent of the Studio/Performer:
   • only scanned coloured HR copy of the document, will be accepted for examination
   • sources of electronically held information must have been risk-assessed prior to use.
3. In cases where a Platform User cannot produce acceptable documents, the responsible AC Officer will make a risk-based decision on accepting the documents that are available., consulting with the MLRO if appropriate.
4. Where the Studio Manager/Performer is not a European resident, or will not be seen in person (that means via the webcam) by the member of staff carrying out the verification, the responsible AC Officer will make a risk-based decision on the means of verification to be accepted., consulting with the MLRO if appropriate.
   

Check of the beneficial ownership

1. Where the Performer is not the beneficial owner of assets involved, the responsible AC Officer will take the necessary steps to determine who is the beneficial owner, and take reasonable measures to verify their identity, according to this procedure.
2. The MLRO will prepare a format for use by the responsible AC Officer in requesting verification of identity and beneficial ownership information from the Studio/Performer and a procedure for following up when requests are not met within the statutory period.
3. If all possible means of identifying the beneficial owner of a non-individual Studio/Performer have been exhausted without success, and recorded, the responsible AC Officer will seek the approval of the MLRO, to be given on a risk-sensitive basis, to treat as its beneficial owner the senior person responsible for managing the non-individual Studio/Performer.
4. In respect of the ultimate beneficial owner(s) of the non-individual Studio’s/Performers the following information is required:
   • Title
   • Name and surname
   • Country of residence
   • Address
   • Date of birth
   • Country of birth
   • Id number
   • Reason why the individual is UBO (percentage of direct or indirect capital/ownership etc.)
5. Where the Platform User is a listed company or a regulated firm, the responsible AC Officer will check that the Platform User is appropriately registered, and that the person with whom AC Group is dealing is properly authorised to act on the Platform Users behalf, and will verify the identity of that person according to this procedure, in addition to that of the non-individual Studio/Performer.
6. In all cases assessed as presenting a higher money laundering risk, where enhanced Platform User due diligence is required, the responsible AC Officer will consult with the MLRO to decide on additional steps to verify the Platform User’s identity.
7. All verification of identity processes as well as actions taken to verify the identity of non-individual Studio/Performer will be recorded. This will include keeping photocopies of all documents produced and email exchanges.
8. For both the individual and the non-individual Studio’s/Performers, the responsible AC Officer will collect reference information of the bank account of such Studio/Performer:
   • Bic or IBAN
   • Name of the institution where the account is held
   • Address of said institution
9. For both the individual Performers/Studio’s and the beneficial owners of the non-individual Performers/Studio’s, it will be monitored whether such person qualifies as a “politically exposed person”. When opening an account the following questions will be asked:
   • Are you a politically exposed person that is are you an individual who is or has been entrusted with a prominent function.  Y/N
   • Are you linked with such a person (family, close associate) ? Y/N
   • If yes, please indicate the name and the function of the person justifying this status.

POLICY AND PROCEDURE FOR KNOWING THE PLATFORM USER’S BUSINESS AS PART OF CUSTOMER DUE DILLIGENCE (CDD)

POLICY

It is the policy of AC Group to obtain information enabling to assess the purpose and intended nature of every Platform User’s relationship with AC Group. This Know Your Client’s Business information will enable AC Group to maintain our assessment of the on-going money laundering risk, and notice changes or anomalies in the Platform User’s arrangements that could indicate money laundering.
It is the policy of AC Group not to offer its services, or to withdraw from providing its services on the platform, if a satisfactory understanding of the nature and purpose of the Platform User’s business cannot be achieved.

CONTROLS AND PROCEDURES (security management as laid down in the document “Policy AML and Fraud Tools”)

1. The responsible AC Officer will obtain Know Your Client’s Business information from Studio’s/Performers (both individual and non-individual) on the platform:
   • on acceptance of Studio’s/Performers on any significant change in the Studio’s/Performers agreements such as the size or frequency of transactions, nature of business conducted, involvement of new parties or jurisdictions as an ongoing exercise throughout the relationship with the Platform User.
2. Know Your Client’s Business information sought from Platform Users will include, but not be limited to:
   • the purpose or need and business justification of the services the Platform User is selling on the platform as a Studio/Performer to the Users and by using the E-wallet for the pay-outs to the Platform Users..
     
   • the provenance of funds or assets involved in the Platform User’s sales.
   • the nature, size, frequency, source and destination of anticipated transactions of the Studio/Performer (volume and destination of the transactions).
   • the business justification for all uses of structures and entities (if applicable).
   • the counter-parties and jurisdictions concerned.
3. The information will be obtained by asking the Platform User pertinent questions, and the answers given by the Platform User will be verified where this is possible within the course of normal conduct of the relationship (survey Platform User).
4. Information provided by the Platform User will be recorded on the Platform User account, to assist with future monitoring of the Platform User relationship (Flag on account monitoring).
5. Answers not readily verifiable should nevertheless be considered together with other details known about or given by the Platform User to check that all the information is consistent and plausible.
6. Where answers given by the Platform User are implausible, or inconsistent with other information, or where the Platform User is unwilling to provide satisfactory answers to due diligence enquiries, the responsible AC Officer will consider whether AC Group should commence the relationship or withdraw from the relationship.
7. Know Your Client’s Business information, or the lack of it, will be taken into account by all staff when considering possible grounds to suspect money laundering.

POLICY AND PROCEDURE FOR ONGOING MONITORING OF THEPLATFORM USERS

AC Group shall in any event monitor the following events and seek for a satisfactory explanation:

• Change in banking references
• Change in location
• With respect to the non-individual Studio’s/Performers: Change in the management/change in beneficial ownership

The audits will be performed at the anniversary date that is the date that the Studio/Performer has registered himself on the platform. An alert will notify the team when the controls must be performed.

The consequence of these audits may be the performance of additional steps (request for additional documentation additional checks…), that must be documented in the file of the Platform Users (made of their information, supporting documents, and AML monitoring information).

These audits can as well lead to a new evaluation of the level of scrutiny applied to the Platform User, even up to the end of the business relationship. Such a decision is taken by the AC Group’s owners, on the advises of the MLRO and the responsible of internal control.

POLICY AND PROCEDURE FOR KEEPING RECORDS OF PLATFORM USER DUE DILIGENCE INFORMATION

POLICY

It is the policy of AC Group to establish and maintain systems to keep records of enquiries made and information obtained while exercising Platform User due diligence for AML purposes, and to ensure that these records are retrievable as required for legal and regulatory stipulations. These records will include but not be limited to details recorded for accounting and business development purposes.

CONTROLS AND PROCEDURES

1. When information is being collected for AML Platform User, the responsible AC Officer will ensure that:
   • information collected is recorded in a consistent manner in the Platform User account, or other appropriate place, and that records held in different places are cross- referenced where appropriate, so that information is accessible by and comprehensible to other authorized members of staff, including the MLRO
   • all instances are recorded where information requested has not been forthcoming, or explanations provided have not been satisfactory.
2. AC Group shall have systems to routinely archive records along with AC Group’s accounting records to ensure their availability for a minimum of the legal requirements from the date of the completion of the transaction or enquiry.
3. AC Group shall have data retrieval systems which facilitate full and rapid retrieval of all relevant records by authorised staff, in order to respond fully to enquiries from financial investigators.
4. AC Group shall have procedures to ensure that any personal data obtained is processed only for the purposes of preventing money laundering and terrorist financing.
5. Every document and information collected at the opening of the account, concerning the identity of the Studio/Performer, if applicable its UBO, as well as all of those collected during the business relationship, must be kept during 5 years from the closing of the account. Moreover, each year, the historic of all the transactions performed since the beginning of the year must be kept during 5 whole years. AC Group keeps all the documents in data resulting from their business relationship with the Studio’s/Performers by archiving them according to conditions and modality guaranteeing their integrity, and especially on a permanent support respecting the GDPR rules.
6. AC Group shall provide new Platform Users with the following information prior to registration on the SNV Platform:
   • a statement that any personal data received in respect of the registration will be processed only for the purposes of preventing money laundering and terrorist financing. (GDPR)
7. AC Group shall have a procedure to earmark relevant personal data for deletion at the end of the legal retention period unless:
   • it is required for court proceedings
   • the data subject has given express consent to the retention of that data.
     
8. For registered accounts on the SNV Platform which have been the subject of a suspicion report, relevant records will be retained separately from AC Group’s routine archives, and not destroyed, even after the legal retention period has elapsed, without confirmation from the MLRO that they are no longer required as part of an enquiry.

POLICY AND PROCEDURE FOR INTERNAL SUSPICION REPORTING

POLICY

It is the policy of AC Group that every member of staff shall remain alert for the possibility of money laundering, and shall report any and every suspicion for which they believe there are reasonable grounds, following AC Group’s procedure.
The expectation placed on each individual member of staff in responding to possible suspicions shall be appropriate to their position in AC Group. No-one is expected to have a greater knowledge and understanding than is appropriate to their role.

CONTROLS AND PROCEDURES

1. Every member of staff must be alert for the possibility that AC Group’s services could be used for money laundering purposes, or that in the course of their work they could become aware of criminal or terrorist property.
2. Alertness to the possibility of money laundering must be combined with an appropriate knowledge of Platform User’ normal arrangements so that members of staff become aware of abnormal factors which may represent possible causes of suspicion.
3. A member of staff becoming aware of a possible suspicion shall gather relevant information that is routinely available to them and decide whether there are reasonable grounds to suspect money laundering. Any additional information acquired, in particular any explanations for unusual instructions or transactions, should be recorded on the accounts registered on the platform in the routine manner, but no mention of suspected money laundering is to be recorded in any such accounts.
4. The requirement to gather relevant information does not extend to undertaking research or investigation, beyond using information sources readily available within AC Group.
5. If after gathering and considering routinely available information, the member of staff is entirely satisfied that reasonable grounds for suspicion are not present, no further action should be taken.
6. A member of staff who on consideration decides that there may be grounds for suspicion shall in normal circumstances raise the matter with the responsible AC Officer. If after discussion they both agree that there are no grounds for suspicion, no further action should be taken.
7. No member of staff is obliged to discuss a suspicion of money laundering with the responsible AC Officer. They may, if in the circumstances they prefer, contact the MLRO directly without giving a reason.
8. If following the raising of a possible suspicion by a member of staff, or resulting from their own observations, the responsible AC Officer decides that there are reasonable grounds to suspect money laundering, he or she must submit a suspicion report to the MLRO, in the format specified by the MLRO for that purpose.
9. An internal suspicion report does not lead to the breach of confidentiality, and no member of staff shall fail to make an internal report on those grounds.
10. If a suspicion report results from a matter raised by a member of support staff, the responsible AC Officer must advise them in writing that a report has been submitted by reference to the matter discussed on the given date, without including the name of the person(s) suspected. This confirms to the member of staff who raised the matter that their legal obligation to report has been fulfilled. (reporting procedure format)
11. In the circumstance where any member of staff forms a suspicion of money laundering but the responsible AC Officer does not agree that there are reasonable grounds for suspicion, the member of staff forming the suspicion must fulfil their legal obligation by submitting a money laundering suspicion report to the MLRO, in the format specified by the MLRO for that purpose. The responsible AC Officer must recognise this legal requirement and assist the staff member in fulfilling it.
12. A member of staff who forms or is aware of a suspicion of money laundering shall not discuss it with any outside party, or any other member of staff unless directly involved in the matter causing suspicion.
13. No member of staff shall at any time disclose a money laundering suspicion to the person suspected (including an outside party). If circumstances arise that may cause difficulties, the member of staff must seek and follow the instructions of the MLRO.
14. No copies or records of money laundering suspicion reports are to be made, except by the MLRO who will keep such records secure, and separate from AC Group’s Platform User accounts and other repositories of information.

POLICY AND PROCEDURE FOR FORMAL DISCLOSURES TO THE AUTHORITIES

POLICY

It is the policy of AC Group that the Money Laundering Reporting Officer (or if absent, the deputy MLRO) shall receive and evaluate internal suspicion reports, and decide whether a formal disclosure is to be made to the authorities. If so deciding, the MLRO will make the formal disclosure on behalf of AC Group, using the appropriate mechanism.

CONTROLS AND PROCEDURES

1. On receipt of a money laundering suspicion report from a member of staff, the MLRO shall acknowledge its receipt in writing, referring to the report by its date and unique file number, without including the name of the person(s) suspected. This confirms to the member of staff that their legal obligation to report has been fulfilled.
2. The MLRO shall open and maintain a log of the progress of the report. This log shall be held securely and shall not form part of the Platform User account.
3. Following receipt of a report, the MLRO shall gather all relevant information held within AC Group, and make all appropriate enquiries of members of staff anywhere in AC Group, in order properly to evaluate the report. The MLRO shall then decide whether they personally believe there are reasonable grounds for suspicion, and make a decision on AC Group’s obligation to make a formal disclosure to the authorities.
4. Before actually making a formal disclosure to the authorities, the MLRO will have to seek advice from AC Group’s owner. AC Group’s owner will have the final decision on whether to make a formal disclosure to the authorities.
5. All members of staff, anywhere in AC Group, shall respond in full to all enquiries made by the MLRO for the purposes of evaluating a suspicion report. Information provided to the MLRO in response to such enquiries does not breach any confidentiality/professional privilege, and no member of staff shall withhold information on those grounds.
6. If it has been decided that a formal disclosure to the authorities is required, the MLRO shall make such disclosure by the appropriate means.
7. The MLRO shall document in the report log the reasons for deciding to make or not to make a formal disclosure.
8. The MLRO shall where appropriate inform the originator of the internal report whether or not a formal disclosure has been made.
9. The MLRO shall inform all those, and only those, members of staff who need to be aware of the suspicion in order to protect them and AC Group from possible money laundering offences in connection with any related business.
10. Following a formal disclosure, the MLRO shall take such actions as required by the authorities in connection with the disclosure.

POLICY AND PROCEDURE FOR BLOCKING/CONTINUING THE ACCOUNT REGISTRED ON THE PLATFORM FOLLOWING A SUSPICION REPORT

POLICY

It is the policy of AC Group that from the moment a suspicion of money laundering arises, the registered account will be blocked. Neither commercial considerations nor the difficulty in responding to the enquiries of the persons registered on the platform on the matter shall be permitted to take precedence over AC Group’s legal obligations in this regard.

CONTROLS AND PROCEDURES

1. As soon as a member of staff forms or becomes aware of a suspicion of money laundering, the registered account will be blocked.
2. If there is any likelihood of the awareness that the registered account has been blocked, for example because an anticipated transaction has not gone through, the member of staff concerned must contact the MLRO for instructions on how to handle the matter.
3. On receipt of a suspicion report, the MLRO shall instruct the originator of the report and any other staff involved to block the registered account giving rise to suspicion
4. When an registered account has been blocked, the MLRO shall carry out the evaluation of the suspicion report as quickly as possible to decide whether a disclosure must be made to the authorities.
5. If the MLRO decides that there are not reasonable grounds to suspect money laundering, he or she will give consent for continuing the registered account on his or her own authority.
6. If the MLRO decides that a disclosure must be made, he or she will request consent to continue from the AC Group’s owner as quickly as possible. The AC Group’s owner will have the final decision on AC Group’s continuation of the registered account.

POLICY AND PROCEDURE FOR AML TRAINING

POLICY

It is the policy of AC Group that recruitment of all new staff will include assessment as described in section 48(2) of the European Money Laundering Regulations. (source PDF 2018 European directives AML). Screening will take place prior to appointment and at regular intervals during the appointment of all staff.
It is the policy of AC Group that all staff who handle the registered accounts, or access to the registered accounts, shall receive anti-money laundering training to ensure that their knowledge and understanding is at an appropriate level, and ongoing training at least annually to maintain awareness and ensure that AC Group’s legal obligations are met.
It is the policy of AC Group that all staff who handle the registered accounts, or access to personal data relating to such accounts, shall receive training on the law relating to data protection to ensure that their knowledge and understanding is at an appropriate level, and ongoing training at least annually to maintain awareness and ensure that AC Group’s legal obligations are met.
The MLRO shall, in co-operation with AC Group’s training officer and data protection officer, ensure that training is made available to staff according to their exposure to money laundering and data protection risk, and that steps are taken to check and record that training has been undertaken and that staff have achieved an appropriate level of knowledge and understanding.
In the light of the seriousness of the obligations placed on each individual by the Law and the Regulations, and the possible penalties, the MLRO shall ensure that information about these personal obligations is available to all members of staff at all times.
The goal of the training is:

• To develop AML reflexes
• rise each staff member awareness, in order to maintain their AML reflexes
• update collective and operational knowledge of the AML risks
• train the staff members to detect suspicious cases
• train these staff members to formalize new type cases with potential risks
• check the appropriate knowledge of the procedures and the subsequent obligations,

The training of all the newly hired staff is part of their integration process, under the responsibility of the head of internal control. The head of compliance hold the training session. The session can be held by web conference.
The training supports and attendance sheets, must be kept for at least 5 years after the departure of the specific collaborator.

CONTROLS AND PROCEDURES

1. Post appointment, staff assessment according to section 48(2) of the European Money Laundering Regulations will be incorporated into AC Group’s regular staff appraisal process.
2. The MLRO will, in co-operation with AC Group’s training officer, evaluate alternative AML training methods, products and services in order to make suitable training activities available to all members of staff who handle the registered accounts.
3. Suitable training will take into account:
   • the need to achieve a level of knowledge and understanding appropriate to the individual’s role in AC Group
   • the need to maintain that level through ongoing refresher training
   • the practicality of assigning different programs to staff with different roles on a risk- sensitive basis
   • the cost and time-effectiveness of the alternative methods and media available.
4. The training program will include means of confirming that each individual has achieved an appropriate level of knowledge and understanding, whether through formal testing, assessment via informal discussion, or other means.
5. Special consideration will be given to the training needs of senior management, and of the compliance team.
6. The MLRO will:
   • inform every member of staff of the training program that they are required to undertake, and the timetable for completion
   • check that every member of staff has completed the training program assigned to them, issuing reminders to any who have not completed to timetable
   • refer to the business owner any cases where members of staff fail to respond to reminders and have not completed their assigned training
   • keep records of training completed, including the results of tests or other evaluations demonstrating that each individual has achieved an appropriate level of competence.
7. On completion of a training cycle, the MLRO will ensure the continuity of ongoing training while giving consideration to:
   • the effectiveness of the program completed
   • the need to keep training information up to date with changes in laws, regulations,
   • guidance and practice.
8. The MLRO will determine the training needs of his or her own role, and ensure that he or she obtains appropriate knowledge and understanding as required to fulfill the obligations of the appointment.

POLICY AND PROCEDURE FOR THE MONITORING AND MANAGEMENT OF COMPLIANCE

POLICY

It is the policy of AC Group to monitor our compliance with legal and regulatory AML requirements and conduct an annual independent AML compliance audit, the findings of which are to be considered and appropriate recommendations for action set out.
AC Group’s owner shall provide the necessary authority and resources for the ongoing implementation of a compliant AML regime.

CONTROLS AND PROCEDURES

1. The MLRO will monitor continuously all aspects of AC Group’s AML policies and procedures, together with changes and developments in the legal and regulatory environment which might impact AC Group’s business-wide risk assessment. Any deficiencies in AML compliance requiring urgent rectification will be dealt with immediately by the MLRO, who will report such incidents to AC Group’s owner when appropriate and request any support that may be required.
2. The MLRO will facilitate and assist the independent auditor in conducting an annual audit of AC Group’s AML compliance. This report will include:
   • a summary of AC Group’s money laundering risk profile and vulnerabilities, together with information on ways in which these are changing and evolving
   • a summary of any changes in the regulatory environment(s) in which AC Group operates and the ways in which AC Group is affected
   • a summary of AML activities within AC Group, including the number of internal suspicion reports received by the MLRO and the number of disclosures made to the authorities
   • details of any compliance deficiencies on which action has already been taken, together with reports of the outcomes
   • details of any compliance deficiencies on which action needs to be taken, together with recommended actions and management support required
   • an outline of plans for the continuous development of the AML regime, including ongoing training and awareness raising activities for all relevant staff.
3. Where management action is indicated, AC Group’s owner will decide the appropriate action to be taken.