Legal Compliance
Anti-Money Laundering and Counter-Terrorism Financing Policy
Karaca Ambalaj's policy on preventing money laundering and terrorism financing (AML/CTF). Know Your Customer principle and compliance program.
Policy Purpose
Karaca Ambalaj aims to support all efforts at both national and international levels in combating money laundering, terrorism financing, and related crimes, and to comply with all laws and other legal regulations.
What is Money Laundering?
Money laundering can be defined as concealing the illegal source of proceeds obtained from crime.
Stages of Money Laundering
The money laundering process generally consists of 3 stages:
| Stage | Description |
|---|---|
| Placement | Introducing criminal proceeds into the financial system |
| Layering | Distancing criminal proceeds from their source |
| Integration | Introducing funds whose connection to illegal sources has been severed into the financial system in a laundered form |
Commercial institutions can be used at any stage of the money laundering process. Even if unintentional, there is a risk of reputational damage to an organization involved in money laundering.
Our Core Principles
- Compliance with all legal regulations
- Cooperation with regulatory authorities at national and international levels
- Compliance with ethical business principles
Karaca Ambalaj is supervised by the Ministry of Finance of the Republic of Turkey and complies with legal regulations.
Our Compliance Program
Karaca Ambalaj develops and implements a comprehensive program to comply with legal regulations on the prevention of money laundering and terrorism financing, both in Turkey and in other countries where it operates.
Program Scope
- Written policies and procedures
- Auditing to test the effectiveness and developments of the program in practice
- Internal audit and control system to ensure compliance with legal regulations
- Providing relevant personnel with training on the subject
Policies and Procedures
1. Know Your Customer (KYC) Principle
The “Know Your Customer” principle lies at the foundation of Karaca’s customer acceptance policy regarding the prevention of money laundering and terrorism financing.
KYC scope includes:
- Having accurate and sufficient information about customers
- Monitoring transactions
- Monitoring whether the activities of customers and/or suppliers are compatible with their income, assets, and profession information
- Ensuring that the identity verification of customers and/or suppliers is done timely, completely, and accurately in accordance with current legislation and company policy
2. Establishing Business Relationships
- Business relationships with customers and/or suppliers are not entered into without obtaining the necessary information and documents
- Business relationships with anonymous or code names are not permitted
- Blacklist checks are performed in customer acceptance
3. Retention
- Customer information and documents, records related to transactions are retained for 8 years
4. Suspicious Transaction Reporting
- All suspicious transactions are reported to relevant authorities
- Reports are also made to foreign authorities when requested for cooperation
- Company employees are ensured to exercise due care
5. National and International Cooperation
- Work is conducted in cooperation with regulatory authorities when necessary
Organization and Compliance Officer
Organization
Within Karaca, evaluation of activities is carried out with support from relevant departments regarding financial, administrative, and legal matters.
Compliance Officer Responsibilities
The Compliance Officer, who serves to ensure that activities are conducted in compliance with regulations and industry rules and principles:
- Carry out necessary work to ensure compliance with regulations
- Ensure communication and coordination
- Ensure the execution of the compliance program
- Manage evaluation, monitoring, and control activities
- Track training activity results
- Submit the training program for Board of Directors approval
- Research and evaluate suspicious transactions
- Report transactions deemed suspicious to the General Manager
The Compliance Officer works in cooperation with Finance, Operations, and Legal Advisors while fulfilling these duties.
Employee Protection
Suspicious transaction reports are notifications that the state maintains with maximum confidentiality, and the Laws of the Republic of Turkey have established maximum security measures for reporting individuals.
Company employees carry out transactions with the assurance that they will not face any negative treatment or sanctions due to their compliant behavior.
Additional Measures for High-Risk Transactions
The following additional measures are taken for groups identified as high risk as a result of risk assessment:
- Development of procedures for continuous monitoring of transactions and customers
- Making the establishment of business relationships, continuation of existing business relationships, or execution of transactions subject to senior management approval
- Obtaining information to the extent possible about the purpose of the transaction and the source of the assets involved
- Obtaining additional information and documents within the scope of customer identification
- Taking additional measures regarding confirmation and documentation of information provided