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Individual public memo

Identification of persons belonging to Public Figures, close persons of Public Figures, related persons of national Public Figures, foreign Public Figures, personalities performing political functions in international organizations and family members of the client

According to the Law of Ukraine " On preventing and counteracting to legalization (laundering) of the proceeds of crime, terrorist financing, and financing proliferation of weapons of mass destruction"

Art.1 p.1  (25)

National Public Figures - individuals who perform or have performed certain public functions in Ukraine over the past three years, namely:

President of Ukraine, Prime Minister of Ukraine, members of the Cabinet of Ministers of Ukraine;

First deputies and Deputy Ministers, Heads of other central executive bodies, their first deputies and other deputies;

People’s Deputies of Ukraine;

Chairman and members of the Management Board of the National Bank of Ukraine, members of the Board of the National Bank of Ukraine;

Chairmen and judges of the Constitutional Court of Ukraine, the Supreme Court of Ukraine and higher specialized courts;

Members of the Supreme Council of Justice, members of the High Qualification Commission of Judges of Ukraine, members of the Qualification and Disciplinary Commission of Prosecutors;

The Prosecutor General and his deputies;

Chairman of the Security Service of Ukraine and his deputies;

Director of the National Anti-Corruption Bureau of Ukraine and his deputies;

Chairman of the Antimonopoly Committee of Ukraine and his deputies;

Chairman and members of the Clearing House;

Members of the National Council for Television and Radio Broadcasting of Ukraine;

Ambassadors Extraordinary and Plenipotentiary;

Chief of the General Staff - Commander-in-Chief of the Armed Forces of Ukraine, Chiefs of the Ground Forces of Ukraine, Air Forces of Ukraine, Naval Forces of Ukraine;

Civil servants whose positions belong to category "A";

heads of regional territorial bodies of central executive authorities, heads of prosecutor's offices, heads of regional territorial bodies of the Security Service of Ukraine, Chairmen and Judges of Appeal Courts;

heads of administrative, managerial or supervisory bodies of state and state-owned enterprises, business entities whose state share in the authorized capital exceeds 50 percent;

heads of governing bodies of political parties and members of their central statutory bodies;

Art.1 p.1 (19)

Foreign Public Figures - individuals who perform or have performed certain public functions in foreign countries over the past three years, namely:

Head of State, head of government, ministers and their deputies;

Members of Parliament;

Chairmen and board members of central banks;

Members of the Supreme Court, the Constitutional Court or other judicial bodies whose decisions are not subject to appeal, except for appeal in exceptional circumstances;

Ambassadors Extraordinary and Plenipotentiary, charge d'affaires and heads of Central Military Administration bodies;

Heads of administrative, managerial or supervisory bodies of state-owned enterprises of strategic importance;

Heads of governing bodies of political parties represented in Parliament;

Art.1 p.1 (13)

Figures performing political functions in international organizations

Officials of international organizations who hold or have held senior positions in such organisations for the past three years (directors, chairmen of boards or their deputies), or perform any other senior functions at the highest level, including in international interstate organizations, members of international parliamentary assemblies, judges and senior officials of international courts;

Art.6 p.5 (2)

Related persons to national Public Figures, foreign Public Figures, figures performing political functions in international organizations are persons as follows

  • with which family members of National, Foreign Public Figures, figures performing political functions in international organizations have business contacts or personal relations;
  • legal entities whose ultimate beneficial owners (controllers) are Public Figures or their family members, or persons with whom Public Figures have business contacts or personal relations.

Comply with instructional guidelines on the organization of financial monitoring of the state financial monitoring service of Ukraine

Section I p.1.4

Business contacts - documented (in particular, with title documents) connections that arise between family members of Public Figures and individuals in the context of, in particular:

property rights (joint ownership, the use or disposal of assets of family members of Public Figures (for example: an individual has a share on the right of common shared or common joint ownership, in particular, equipment, transport, other movable and immovable property, etc. in an enterprise owned by a family member of a Public Figure or his close relative. And this ownership right is certified by the relevant document);

control, that is, the ability to exercise a decisive influence on the economic activity of a business entity, which is carried out, in particular, by exercising the right to own or use all assets or a significant part of them, the right to decisive influence on the formation of the composition, the results of voting and decision-making by the management bodies of the business entity, as well as making of transactions that provide an opportunity to determine conditions of economic activity, to give mandatory instructions or to perform functions of the management body of the business entity;

representative offices: (a) representation based on an administrative act; (B) representation based on law (representation by law); (c) representation based on a contract (voluntary or contractual representation); (d) commercial representation;

holding senior positions in the management bodies of a business entity;

business partnerships.

Personal relations - connections arising between family members of Public Figures and individuals, in particular, in the context of the right to use the assets of family members of Public Figures, regardless of formal ownership (for example: it is known that an individual lives together with a family member of a Public Figure or lives in housing, at the expense of family members of a Public Figure, etc).

Comply with the Law of Ukraine “On prevention of corruption”

Art.1  p.1

Close persons

- family members of the subject specified in part one of Article 3 of this Law, as well as husband, wife, father, mother, stepfather, stepmother, son, daughter, stepson, stepdaughter, native and cousin-brother, native and cousin-sister, brother and sister of the wife (husband), nephew, niece, native uncle, native aunt, grandfather, grandmother, great-grandfather, great-grandmother, grandson, granddaughter, great-grandson, great-granddaughter, son-in-law, daughter-in-law, father-in-law, mother-in-law, father of the husband, mother of the husband, father of the wife, mother of the wife, father and mother of the wife (husband), son (daughter), adoptive parent or an adopted, guardian or trustee, a person who is under the guardianship of the specified subject;

Art.1 p.1

Family members

а) a person married to the subject specified in part one of Article 3 of this Law, and the children of the specified subject before they reach the age of majority - regardless of cohabitation with the subject;

б) any persons who live together, and are connected by a common way of life, have mutual rights and obligations with the subject specified in part one of Article 3 of this Law (except for persons whose mutual rights and obligations are not of a family nature), including persons who live together, but are not married.

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