Anti Fraud Policy

1. POLICY STATEMENT

Moonable UAB creates a secure and trustworthy environment for its users by offering reliable services. We are committed to conducting our business by the highest standards of ethics, integrity, and compliance with all applicable laws. Our clients, partners, and the public have the right to expect that Moonable UAB operates with professional, competent, and trustworthy personnel.

Moonable UAB adheres to a ‘zero tolerance’ stance towards fraud, corruption, collusion, money laundering, the financing of terrorism, and other forms of criminal activity (hereinafter collectively referred to as “Prohibited Conduct”). We are dedicated to thoroughly investigating any instances of Prohibited Conduct and will take appropriate disciplinary and/or legal action against those found responsible.

Moonable UAB will allocate adequate and appropriate resources to implement this Anti-Fraud Policy and will ensure it is effectively communicated and understood by all stakeholders.

2. LEGISLATION COMPLIANCE

This Anti-Fraud Policy has been formulated to comply with prevailing local and international laws, including relevant EU legislation. Moonable UAB commits to continuous compliance with all pertinent legislation and internal policies.

3. DEFINITIONS

In the context of this Anti-Fraud Policy, Prohibited Conduct encompasses:

•  Fraud: Deliberate deception, including misrepresentation, made for personal gain or to damage another individual or entity.
• Corruption: Direct or indirect actions involving offering, giving, receiving, or soliciting anything of value to influence the actions of another party improperly.
•  Collusion: A secret agreement or cooperation between two or more parties for an illegal or deceitful purpose.
•  Money Laundering: Activities aimed at legitimizing the proceeds of crime.
•  Financing of Terrorism: Providing or collecting funds with the intention or knowledge that they will be used to support terrorist activities.
• Criminal Conduct: Actions constituting an offense in any jurisdiction or actions that would be an offense if they occurred in any jurisdiction.

4. KEY RESPONSIBILITIES

Moonable UAB enforces a rigorous ‘Know-Your-Customer’ (KYC) policy and due diligence on all transactions to identify and mitigate potential risks. As part of our Anti-Fraud Policy, Moonable UAB is responsible for:

   – Establishing effective systems, procedures, and internal controls to prevent and detect Prohibited Conduct.

   – Ensuring that the Anti-Fraud Officer identifies risks of Prohibited Conduct and that all controls are properly enforced.

   – Obligating all members of the anti-fraud department to report any suspicions or incidents of Prohibited Conduct.

   – Continuously reviewing and updating systems, procedures, and controls through risk management and audit processes.

   – Report any suspicions of prohibited conduct to the appropriate authorities.

5. FRAUD DETECTION AND INVESTIGATION

The Operational Anti-Fraud Department at Moonable UAB, particularly the Anti-Fraud Officer, is the primary agent in detecting, investigating, and preventing Prohibited Conduct. The Anti-Fraud Officer is responsible for:

   (a) Authority: Receive and investigate reports of alleged or suspected Prohibited Conduct, collaborate with the Nominated Officer for KYC compliance, and report findings to Moonable UAB’s management and relevant authorities.

   (b) Independence: Operating autonomously in conducting investigations. 

   (c) Professional Standards: Ensuring all investigations are conducted fairly, impartially, and with due respect for the rights of all parties.

   (d) Cooperation: Requiring all users and employees to cooperate with the Operational Anti-Fraud Department in investigations fully.

   (e) Confidentiality: Maintaining strict confidentiality of information and documents collected during investigations, except when disclosure is authorised or legally mandated.

6. DETECTED FRAUD REPORTING PROCEDURE

Initial Identification: Employees or users who suspect fraudulent activity first are informed to document it. Company is offering two ways to report the fraud: 

(a) [email protected]

(b) fill an anonymous online form. 

Anonymous Reporting: Offer an option for anonymous reporting to encourage more individuals to come forward without fear of retaliation. This is facilitated through a third-party service, an anonymous online form. (GoogleForms) 

7. TRAINING AND AWARENESS PROGRAMS

To combat fraud effectively, Moonable UAB implements comprehensive training and awareness programs with the following elements:

• Regular Training Sessions: Periodic training sessions for all employees to educate them about the types of fraud risks, how they manifest in the crypto industry, and the latest trends in fraudulent schemes.
• Interactive Learning: Utilizes interactive learning methods like workshops, webinars, and role-playing scenarios to engage employees actively in fraud detection and prevention strategies. Mainly offered by the Lithuanian AML center. 
• Policy Education: Ensure all staff are thoroughly familiar with the company’s anti-fraud policy, including reporting procedures and their role in preventing fraud.

8. MISCELLANEOUS

Moonable UAB commits to regularly reviewing and updating this Anti-Fraud Policy to reflect new legal and regulatory developments and ensure best practices.

Declaration: By engaging with Moonable UAB, I affirm that I do not intend to engage in any Prohibited Conduct as outlined in this policy. I consent to any checks or investigations under this Anti-Fraud Policy and agree to fully and promptly cooperate with the Anti-Fraud Officer during such investigations.

For further support or to report any suspicious activity, don’t hesitate to contact us at [email protected]