D&P Anti-Money Laundering Policy

D&P Anti-Money Laundering Policy

Doklestic Repic & Gajin z.a.k., with registered seat at address Bulevar oslobodjenja no. 203, 11000 Belgrade, Republic of Serbia (hereinafter: “D&P”) is dedicated to prevention of money laundering and financing of terrorism.

D&P as one of the obligors of the Law on Prevention of Money Laundering and Financing of Terrorism (hereinafter: the “Law”) is taking all legal actions and measures with special care in order to prevent and detect money laundering and financing of terrorism.

In prevention of money laundering and financing of terrorism, D&P has certain legal obligations towards competent authorities, including the Administration for the Prevention of Money Laundering (hereinafter: the “Administration").

In prevention of money laundering and financing of terrorism D&P is in particular taking the following actions: (i) knowing our clients and their business, (ii) delivery of information, data and documents to the Administration, etc.

Actions and Measures of Conversance and Monitoring of a Party

In the implementation of actions and measures of conversance and monitoring of the party the D&P is obliged to comply with the Law and to request information of its clients in order to:

  1. determine the identity of a client;
  2. verify identity of the client on the basis of documents, data or information obtained from a reliable and trustworthy sources;
  3. determine the identity of the real owner of client and verify his/her identity as required by the Law;
  4. obtain information on the intent and purpose of the business relationship or transaction and other information in accordance with the Law;
  5. carry-out regular monitoring of business operations and checking for compliance of activities of the client with the nature of the business relationship and the common size and type of business of the client.

D&P will take all aforementioned actions especially in the following cases:

  1. when establishing a business relationship with a client,
  2. when there is doubt relating to the veracity or authenticity of obtained data about the client and the real owner.

D&P will especially pay attention to implement the above mentioned actions and measures for preventing and detecting money laundering and financing of terrorism in the following cases:

  1. when helping in planning or execution of transactions for a client concerning the:
    • purchase or sale of real property or of a company;
    • managing clients’ assets;
    • opening or disposal of the account with the Bank (bank account, savings account or for account for operations with securities);
    • collection of funds needed for the establishment, performing the activity and management of companies;
    • incorporation, operation or management of a foreign law person.
  2. when in the name and for the account of the client performs a financial transaction or a transaction related to real property.

Indicators for Detecting Suspicious Transactions

D&P in its work in particular applies the indicators for recognizing suspicious transactions for lawyers and law firms which are defined by the Administration.

Notifying of the Administration

D&P has a legal obligation, in certain cases defined by the Law, to inform the Administration about suspicious transactions.

However, D&P is not obliged to notify the Administration in the event of obtaining of information it receives from a party or relating to party to verify its legal position or its representation in court proceedings or in connection with court proceedings, including giving advice on starting or avoidance of that procedure, regardless of whether the information was obtained before, during or after court proceedings.

D&P must not discover to its client or any third party that certain information was submitted to the Administration.

Legal Actions

D&P is not obliged and will refuse to undertake any action for which there is a suspicion that is contrary to the Law, i.e. for which there is suspicion that ultimately presents money laundering or financing of terrorism.

Final Provisions

This Policy on Prevention of Money Laundering and Financing of Terrorism is binding for all employees, attorneys, lawyers, associates, agents and consultants of D&P, who are required to respect it and to comply with it.

Violation of this Policy represents a legitimate reason for D&P to cease co-operation with the person responsible for violation of its provisions. Also, the D&P will, in accordance with its legal obligations, report such behavior to competent authorities.

This Policy on Prevention of Money Laundering and Financing of Terrorism shall enter into force and become applicable from 01 May 2016.