The policy of Alma Íbúðafélag hf. on measures against money laundering and terrorist financing
Alma íbúðafélag hf. (Alma) has dedicated itself to ensuring the reliability of its customers and mapping risks in the company's operations, taking into account the provisions of Act no. 140/2018 on measures against money laundering and terrorist financing.
This policy covers all of the company's activities in those cases where it is considered a notifiable party within the meaning of paragraph 1. Article 3, cf. Paragraph 1 Article 2 of the law and conducts business or other operations that fall within the scope of the law.
1.Purpose and legal obligation
The company focuses on complying with all provisions of the law and this policy is based on law no. 140/2018 on measures against money laundering and terrorist financing.
The aim of the law is to prevent money laundering and the financing of terrorism by obliging entities that engage in activities that may be used for money laundering or terrorist financing to know the identity of their customers and their activities and to report it to the competent authorities if suspicions or awareness arise of such illegal activities.
The field of activity of companies in rental operations has been defined among those that may be used for such purposes, and Alma is therefore obliged to comply with the more specifically specified provisions of the law.
2. Actions based on the law
Alma has had a risk assessment of its operations and business carried out on the basis of Article 5. of the law, but the assessment is renewed every two years. Alma also conducts due diligence on its customers as appropriate on the basis of III. section of the Act. Alma has also appointed a guarantor on the basis of Article 34. of the law.
3. Risk assessment
Alma has had a risk assessment of its operations and business carried out in accordance with Article 5. of the law. The assessment was carried out by an independent, external party and was therefore completed in 2019. The risk assessment will be updated no later than in 2021 and Alma has implemented work processes to ensure that it will be carried out, along with other obligations that the law imposes on the company.
4. Due diligence
Alma carries out due diligence in accordance with III. section of the law in the cases considered in Article 8. In the activities of Alma, point a of paragraph 1. Article 8 of the Act is particularly practical, as the company regularly establishes new ongoing contractual relationships within the meaning of the provision. It applies at the beginning of the rental relationship with customers, but also in cases where Alma performs administration for the landlord.
The process is different depending on whether Alma's customers are individuals or legal entities.
In the case of individuals, more detailed information is requested that Alma considers necessary to start a business relationship, cf. further description in the company's privacy policy. In addition to that information, individuals are required to present approved identity documents in accordance with point a of paragraph 1. Article 10 of the law. A copy is taken of the identity card and preserved in accordance with paragraph 1. Article 28 of the law.
In the case of legal entities, they are required to provide, in addition to the information that Alma deems necessary to start a business relationship, information from the Swedish Tax Administration's company register or similar public register with name, address and social security number or similar information to prove their identity, in accordance with clause section b of 1. paragraph Article 10 of the law. The representative of the legal entity is also required to prove his identity by presenting authorized identity documents in accordance with the same provision, cf. and point a of paragraph 1 Article 10 of the law. A copy is taken of the aforementioned data and preserved in accordance with paragraph 1. Article 28 of the law.
5. Guarantor
Alma has appointed a guarantor in accordance with the provisions of Article 34. of the law. The responsible person handles notifications in accordance with Article 21. of the law as well as other communications with the police financial analysis office as appropriate and also has unconditional access to customer due diligence, transactions or requests for transactions as well as other necessary data.
Alma's guarantor is Ingólfur Árni Gunnarsson, the company's managing director.
6. Privacy
Alma places great emphasis on strict compliance with law no. 90/2018 on personal protection and processing of personal information and has adopted a detailed personal protection policy that is publicly published on the company's website. All of Alma's work described in the above provisions takes into account that the provisions of the Privacy Act and Alma's privacy policy are followed.
For that, it should be considered that Article 28 Act no. 140/2018 provides for the preservation of data and information and Alma fulfills its obligations based on the provision. However, care must be taken not to collect data or preserve it to a greater extent than the provisions of the law require.
More information on the processing and storage of personal information at Alma can be found in the company's privacy policy.
7. Procedures and internal rules
The above list is not exhaustive of actions taken by Alma on the basis of the law. In this way, the company ensures that all other obligations imposed on the company are fulfilled as appropriate. The company has established procedures for the implementation of the aforementioned actions and compliance with the law in other respects, which are presented to employees in detail. The company's lawyer also provides advice and education to staff on the subject of the law as appropriate.
8. Communication with the company
The company can be contacted directly if questions arise about this policy or the company's actions based on Act no. 140/2018. Contact information about the company is as follows:
Alma íbúðafélag hf.
TIN. 611013-0350
Sundagarðar 8
104 Reykjavík
al@al.is
9. Auditing
The company may from time to time change this policy in accordance with changes in relevant laws or the legal environment in other respects. The policy is revised as necessary in the opinion of the board of directors.
This policy was established and approved by the board on January 23, 2020.
