The following conditions are applied by AS Redgate Capital (hereinafter Redgate) to establish a client relationship by means of information technology means where the due diligence measures are not applied while being in the same place as the person or their representative.
When performing the identification and verification of the person’s identity, Redgate is following section 31 of the Money Laundering and Terrorist Financing Prevention Act and the Regulation of the Minister of Finance “Requirements and procedure for Identification of persons and verification of person’s identity with information technology means” (hereinafter Regulation).
Identification pf persons and verification of data does not oblige Redgate to establish a client relationship or to ensure the availability of services. Redgate is entitled to choose with whom they establish client relationship and the general grounds for refusing to establish a client relationship are provided in the General terms and conditions of investment services.
Means and conditions required for a video call:
• Previously filled out and digitally signed client information questionnaire
• Valid identification document (ID card or passport)
• Web camera, microphone, internet connection
The following conditions must be met to identify a person using information technology means:
• a web camera is installed so that the face and shoulders of the person are visible during the entire session;
• room lighting ensures that the face of the person is clearly visible, i.e. recognisable, without any shadows, and well discernible from the background objects;
• the head and face of the person are uncovered;
• the microphone of the information technology means is operational, and sound and image are synchronised, enabling to understand clearly the transmitted text;
• during the interview, the person does not receive any assistance from other persons (with the permission of Redgate, assistance can only be used for eliminating a technical problem);
• the person follows Redgate’s directions, e.g. removes headgear, face cover or glasses, changes the position of the head or body, shows on camera the data or images on documents.
Redgate records all video meetings and preserves these recordings for five years after the end of the relationship as provided by section 47 of the Money Laundering and Terrorist Financing Prevention Act.
The identification of a person and verification of data using information technology means is considered failed if:
• the person or their representative has intentionally submitted data which do not match the data entered into the database of identity documents or other information or data obtained during the session or other processes;
• the session is interrupted or expires in the course of identification, or interview if no operations have been performed for 15 minutes;
• the audio and image information flow does not meet the conditions specified in the Regulation;
• the person or their representative does not give the required confirmations during the session;
• the person or their representative does not follow Redgate’s directions, e.g. does not remove headgear, face cover, or glasses, change the position of head or body, or show on camera the data on the document;
• the person or their representative uses assistance of another person without the permission of Redgate;
• there are circumstances which give rise to suspicions of money laundering or terrorist financing.
If a person submits false, misleading or insufficient information, uses assistance of another person without the permission of Redgate, or does not follow the requirements specified by the investment firm, Redgate may refuse to establish a client relationship with the person.
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