Prevention of money laundering and compliance with international sanctions policy

The main functions and responsibilities in the field of the Prevention of Money Laundering/Terrorist Financing and compliance with International Sanctions policy, are set below:

UAB “TLT PCB“, UAB ‘‘TLT MECHANICS“ and UAB ‘‘ELECTRONICS“ leaders are responsible for:

Appointing of Compliance personnel,

review of suspicious transactions reports,

provide all necessary support, tools, training, and processes to assist employees in understanding their obligations in the Prevention of Money Laundering/Terrorist financing and compliance in the International Sanctions field.

diligent implementation of this Policy and Group internal procedures

review of suspicious transactions reports,

developing a culture of compliance,

communicating the risks and consequences of non-compliance to employees.

Complience specialist is responsible for:

developing and implementing the Prevention of Money laundering/Terrorist financing and compliance with International Sanctions policy and relevant procedures,

prompt responses to information requests by regulators/finance bodies related to Money laundering/Terrorist financing and compliance with International Sanctions,

reporting suspicious transactions to the companies CEO.

Business Development Manager is responsible for:

conducting a Simplified Due Diligence procedure,

clients’ continuous monitoring.

Other staff members are responsible for:

safeguarding TLT from being used by external entities for money laundering, terrorist financing, sanctions violations, or any other illegal purposes,

keeping themselves updated with policies and procedures related to their role at TLT,

escalating potential compliance concerns related to Money laundering/Terrorist Financing and International Sanctions violation risks to the TLT Compliance Team via e-mail compliance@tlt-manufacturing.com.
TLT companies ensure specific and regular training of the most concerned staff. Knowledge of ML/TF/Sanctions is shared on an ongoing basis within the company Group. Furthermore, the training needs of staff members are reviewed at regular intervals to ensure that the objectives of the Prevention of Money Laundering/Terrorist Financing and compliance with International Sanctions policy are met.
TLT companies comply with International Sanctions and trade restrictions, imposed on the EU and US, and any other sanctions regime applicable for particular transactions.

Moreover, concerning Russia’s actions in Ukraine, TLT companies are not conducting business with Russia, Belarus and occupied territories of Ukraine.

TLT products are prohibited for re-export to Russia, Belarus, occupied territories of Ukraine, North Korea, Iran, Syria, and Cuba, and for being used in those territories.
Clients Due Diligence procedure shall be applied at the outset of any business relations to assess clients’ risk.

Simplified Due Diligence

Sales managers are the first line of defence, conducting a Simplified Due Diligence (SDD) procedure for all new clients before entering into business relations.

During the SDD procedure, the following checks are performed:

if there is any negative information about the client in the adverse media,

if the client is not included in the sanctions list,

if trade restrictions will not be violated with the particular transaction (evaluation shall be conducted following the Rules of Compliance with sectoral sanctions in TLT companies).

A low-risk profile is assigned when the client matches with all the above set criteria. High-risk profile assigned where client raises suspicions. Enhanced Due Diligence procedure shall be applied to all high-risk clients.

Enhanced Due Diligence

Enhanced Due Diligence is applied:

where suspicious were escalated from the first line of defence,

initiated by the Compliance Department when changes in legal-regulatory environment or geopolitical situation may cause higher client’s risk. Place of business activity (state) and economic sector shall be primarily considered risk indicators.

The Compliance department, as the second line of defence, conducts a full assessment of clients and ongoing transaction risk, applying the Enhanced Due Diligence procedure. The decision to continue or terminate business relations is made with the presence of the CFO, controlled company CEO, and other decision-making personnel in need.
TLT companies continuously monitor and update the Prevention of Money Laundering/Terrorist Financing and compliance with International Sanctions policy. Monitoring and risk management are implemented in the following ways:

The Policy is regularly updated in response to changes in the legal-regulatory environment to ensure that existing control measures are sufficient to prevent TLT companies from being used as a channel for activities related to Money Laundering/Terrorist Financing/International sanctions violations.

Re-assessment of the client's risk. The client’s risk shall be reassessed annually or at any time when the necessity of the review is triggered by risk indicators.
Following the leading practices, TLT companies ensure they will not engage in business relations with clients presenting unacceptably high compliance and/or reputational risks. In cases when the risk level is intolerable, TLT companies shall not enter into business relations, or terminate it with immediate effect. Decisions on ending business relations must be recorded in TLT‘s internal system.
All information on how we store personal data may be found in TLT Privacy Policy .
Even if making all efforts, no Policy can address every possible ethical or legal situation. Therefore, if you have any AML/CFT/Sanctions related questions,

please contact TLT‘s Compliance Team via e-mail at compliance@tlt-manufacturing.com.
The basis of this Policy is enshrined in the following resources:

EU Council Regulations concerning restrictive measures ;

Export Administrative Rules (EAR) 15 CFR 730-774 ;

EU consolidated financial sanctions list ;

US Office of Foreign Assets Control sanctions program

Internationally trading companies face an increasing risk of financial crimes and International Sanctions or trade restrictions violation. To stay compliant, we have to choose our business partners responsibly. Therefore, we are pleased to inform UAB ‘‘TLT PCB“, UAB “TLT MECHANICS“ and UAB ,“TLT ELECTRONICS“ and all our controlled companies worldwide, hereinafter collectively referred to as ,“TLT”, “we”, “us” and “our”, have established the Prevention of Money Laundering/Terrorist Financing and compliance with International Sanctions policy, reducing the possibility of being used as a channel for Money Laundering (ML) and Terrorist Financing (TF), and to comply with International Sanctions in our business practice.

This Policy is a part of the TLT Compliance process by which we are seeking to:

identify and manage Money Laundering/Terrorist Financing/International sanctions violation risk to which TLT Group companies might be exposed, including risk to reputation,
protect TLT Group companies from being exploited as a channel for Money Laundering, Terrorist Financing, and circumvention of trade restrictions,
ensure that TLT Group companies are compliant with legislative/regulatory provisions of their operating jurisdictions in the field of Money Laundering/Terrorist Financing/International sanctions,
develop an appropriate internal control to detect and report suspicious transactions.

This Policy applies worldwide to all TLT companies and their employees, including, but not limited to, CEOs, VPs, officers, and anyone working on behalf of TLT companies. All employees are expected to act with integrity and responsibility.