ShareX Media EOOD

Last updated: 13 June 2025

1. Introduction

At ShareX Media EOOD, we are fully committed to preventing the use of our services for the purposes of Money Laundering (ML) and Terrorist Financing (TF). We have established robust internal controls and procedures that ensure full compliance with applicable laws, including:

  • EU Anti-Money Laundering Directive (6AMLD)
  • FATF (Financial Action Task Force) Recommendations
  • The Measures Against Money Laundering Act (Bulgaria)
  • EU Regulation 2015/847 on information accompanying transfers of funds

2. Definitions

  • Money Laundering (ML): The process of concealing the origins of money obtained through illegal means by making it appear legitimate.
  • Terrorist Financing (TF): Providing or collecting funds, directly or indirectly, to support terrorist acts or organizations.

3. Scope

This procedure applies to:

  • All employees, partners, and contractors of ShareX Media EOOD.
  • All services and products offered by the company.
  • All transactions and user onboarding processes.

4. Risk-Based Approach

We adopt a Risk-Based Approach (RBA) to assess and mitigate risks associated with ML and TF. This includes:

  • Customer risk assessments
  • Geographic risk analysis
  • Transactional behavior monitoring
  • Product and service risk evaluation

5. Customer Due Diligence (CDD)

We perform Customer Due Diligence (CDD) measures in accordance with Article 13 of the 6AMLD, including:

  • Identity Verification: Collecting valid identification documents (e.g., passport, national ID).
  • Business Verification: For corporate clients, validating legal existence and ownership structure.
  • Ongoing Monitoring: Monitoring transactions to ensure consistency with the customer's profile.
  • Enhanced Due Diligence (EDD): For high-risk customers, including politically exposed persons (PEPs), additional checks are carried out.

6. Record Keeping

  • We retain all customer and transaction records for at least five (5) years after the end of the customer relationship.
  • Records include identity documents, transaction logs, communications, and due diligence reports.

7. Transaction Monitoring

ShareX Media EOOD implements both automated and manual monitoring of transactions to detect:

  • Unusual or complex transaction patterns
  • Transfers to/from high-risk jurisdictions
  • Structuring or "smurfing" behaviors
  • Sudden activity changes

Suspicious activity is flagged and reviewed by our compliance team.

8. Reporting Obligations

We comply with mandatory reporting requirements:

  • Suspicious Transaction Reports (STRs) are submitted to the Financial Intelligence Directorate of the State Agency for National Security (FID-SANS) in Bulgaria.
  • We cooperate fully with competent authorities and provide requested information in a timely manner.

9. Employee Training

All staff are trained annually on:

  • AML/CTF legal requirements
  • Internal procedures
  • Risk indicators and red flags
  • How to handle suspicious activity and report internally

10. Internal Controls & Governance

  • A designated AML Compliance Officer oversees the implementation and enforcement of this procedure.
  • Regular audits and reviews are conducted to assess the effectiveness of AML/CTF controls.
  • Our Board of Directors receives regular updates and oversight reports on AML/CTF compliance.

11. Sanctions Compliance

We strictly comply with EU sanctions, UN Security Council Resolutions, and other international restrictions. Customers and transactions are screened against:

  • Sanction lists (EU, OFAC, UN)
  • Watchlists and PEP lists
  • Adverse media databases

12. Whistleblower Protection

We provide secure and confidential internal reporting channels. Employees who report suspected violations in good faith are protected from retaliation under applicable whistleblower protection laws.

13. Continuous Improvement

We continuously evaluate our policies and procedures in response to:

  • Regulatory updates
  • Industry best practices
  • Internal audits and compliance findings

14. Contact Information

If you have questions about this AML/CTF procedure or wish to report a concern:

📧 [email protected]

📞 +359 87 8544766

ShareX Media EOOD is committed to upholding the integrity of the financial system and protecting our platform from criminal abuse.