Anti-Money Laundering (AML) Policy
Objective
Zero Emissions World (ZEW) is committed to the highest standards of ethics, transparency, and legal compliance. This policy aims to establish guidelines to prevent and combat money laundering (ML) and the financing of terrorism (FT), as required by national and European legislation.
Legal Framework
This policy is aligned with the following legal and regulatory standards:
2.1 National Legislation (Portugal):
Law No. 83/2017, of August 18 – Measures to combat money laundering (ML) and the financing of terrorism (FT), transposing Directive (EU) 2015/849.
Law No. 97/2017, of August 23 – Legal regime applicable to the supervision of compliance with preventive ML/FT obligations.
Regulation of the Bank of Portugal No. 2/2018 – Defines the specific duties of entities subject to the Bank of Portugal's supervision.
2.2 European Legislation:
Directive (EU) 2015/849 – 4th Anti-Money Laundering Directive.
Directive (EU) 2018/843 (5AMLD) – Strengthens control mechanisms, including obligations for transparency regarding beneficial owners.
Directive (EU) 2019/1153 – Access by competent authorities to financial information and combating economic crime.
Regulation (EU) 2023/1113 – Relating to the transfer of funds and the traceability of crypto-assets.
Scope
This policy applies to all ZEW team members, including employees, project managers, consultants, institutional partners, ambassadors, service providers, and any donor whose contribution meets the risk assessment criteria.Definitions:
Money Laundering (ML): The conversion of funds from illicit sources into assets with a legitimate appearance.
Financing of Terrorism (FT): The provision of financial support to individuals or organizations with terrorist aims.
Beneficial Owner: The individual who ultimately owns or controls the entity or funds.
Principles and Procedures
5.1. Know Your Donor/Partner (KYD/KYP)
ZEW applies due diligence measures (donor identification, verification of the origin of funds, and beneficial owner) whenever the donation amount is equal to or exceeds €15,000, even if made in multiple related transactions, as per Article 11 of Law No. 83/2017.
Legal entities must provide proof of registration in the Central Register of Beneficial Ownership (RCBE).
5.2. Risk Assessment and Classification
Depending on the situation, internal risk analysis mechanisms will be used, considering factors such as geographical location, transaction volume, the nature of the entity, and the historical relationship.
Clients or partners from high-risk jurisdictions identified by the EU or the FATF (Financial Action Task Force) will be subject to enhanced due diligence, as required by Law No. 83/2017.
5.3. Transaction Monitoring
Procedures may be implemented to analyze the consistency of transactions with the donor or partner’s profile, based on criteria such as amounts, origin of funds, and type of entity involved.
In this process, donations from opaque legal structures will be identified as potentially suspicious.
5.4. Crypto-assets
ZEW does not accept contributions in crypto-assets.
5.5. Reporting Suspicious Activities
Any suspected ML/FT activity will be reported to the Financial Information Unit of the Judiciary Police (GIF/PJ), as outlined in Portuguese Law 83/2017.
ZEW is committed to cooperating with national and European authorities.
Awareness
All members of the ZEW team are informed about AML/CFT policies.
The organization promotes a "zero tolerance" culture for money laundering and takes proactive measures to identify emerging risks.
Policy Review
This policy will be reviewed annually or whenever there are:
Significant legislative changes;
Changes in ZEW's operational risks;
New funding vectors (e.g., new payment methods, international expansion, etc.).
Institutional Commitment
Zero Emissions World is committed to ensuring that all funds received or moved are in compliance with applicable legal and ethical obligations. Transparency and integrity are core pillars of ZEW's mission to combat climate change.