1. Introduction

Creek & Pine (legal: Supernormal d.o.o, Sveti Petar Orehovec 67, 48267 Orehovec, Croatia, VAT number HR18965816268) is fully committed to the global fight against terrorism and its financing. We recognize the importance of ensuring that our services and operations are not used, directly or indirectly, to support or facilitate terrorist activities. This statement outlines our approach to preventing terrorism financing and the measures we have implemented to comply with applicable laws and regulations.

2. Purpose

The purpose of this statement is to:

  • Demonstrate our commitment to preventing the financing of terrorism.
  • Outline the policies and procedures we have in place to detect and prevent terrorist financing activities.
  • Ensure compliance with all relevant anti-terrorism financing laws and regulations.

3. Legal Framework

Our Anti-Terrorism Financing Policy is based on the following key legislation and regulations:

  • The USA PATRIOT Act
  • The Anti-Terrorism Act
  • The Terrorism Financing Prevention and Suppression Act
  • The Financial Action Task Force (FATF) Recommendations
  • The European Union Anti-Money Laundering Directives (AMLD)
  • The European Union Regulation on the Prevention of the Use of the Financial System for the Purposes of Money Laundering or Terrorist Financing (EU 2015/847)
  • Relevant international sanctions and embargoes

4. Key Principles

Risk Assessment and Management:

  • Conduct regular risk assessments to identify and evaluate potential risks of terrorism financing within our operations.
  • Implement appropriate measures to mitigate identified risks.

Customer Due Diligence (CDD):

  • Perform thorough due diligence on all clients, partners, and stakeholders.
  • Verify the identity of all clients and beneficial owners using reliable and independent sources.
  • Monitor transactions and business relationships on an ongoing basis to ensure consistency with known profiles and expected activities.

Suspicious Activity Reporting (SAR):

  • Establish procedures for the timely detection and reporting of suspicious activities to relevant authorities.
  • Ensure staff are trained to recognize signs of potential terrorism financing and know how to report suspicions.

Training and Awareness:

  • Provide regular training to all employees on anti-terrorism financing laws, regulations, and internal policies.
  • Promote awareness of the importance of preventing terrorism financing and the role each employee plays in maintaining a safe and compliant organization.

Record-Keeping:

  • Maintain comprehensive records of all transactions, customer due diligence information, and reports of suspicious activities.
  • Ensure records are kept for the required statutory period and are readily available for inspection by relevant authorities.

Sanctions Compliance:

  • Screen all clients and transactions against relevant sanctions lists to ensure compliance with international sanctions and embargoes.
  • Refuse to conduct business with any individuals or entities subject to sanctions.

Internal Controls and Audits:

  • Implement robust internal controls to ensure compliance with anti-terrorism financing policies and procedures.
  • Conduct regular audits to review and assess the effectiveness of these controls and make improvements where necessary.

Cooperation with Authorities:

  • Cooperate fully with law enforcement agencies, regulatory bodies, and other relevant authorities in their efforts to combat terrorism financing.
  • Respond promptly to any requests for information or assistance.

    5. Reporting Violations

    Any employee who becomes aware of a violation of this policy, or suspects potential terrorism financing activities, is required to report their concerns immediately to the designated compliance officer. All reports will be treated confidentially and investigated thoroughly.

    6. Conclusion

    Creek & Pine is dedicated to maintaining the highest standards of integrity and compliance in our efforts to prevent terrorism financing. We continuously review and enhance our policies and procedures to ensure they remain effective and in line with current legal and regulatory requirements. By doing so, we contribute to the global fight against terrorism and uphold our commitment to a safer world.

    For further information or to report a concern, please contact our compliance officer at hi@creekandpine.co

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