AML / KYC Policy
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Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy ((this document is an integral annex to the Terms, hereinafter “AML and KYC Policy”):
All terms are understood in the meaning given to them by the Terms.
Due to national and international regulations on the prevention of criminal activities and money laundering, and terrorism financing, the Company (Crypto Technologies LTD, registered in the Republic of Seychelles, company No: 215792, registered office is located at: Suite 1, Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles, which is the administrator of the Website) strictly implements KYC guideline and procedure.
Policy is designated to prevent and mitigate possible risks of Company being involved in any kind of illegal activity while using Website, Platform and any Company’s Services by Users for the cryptocurrency storage purposes (wallet).
Policy covers the following matters:
- Verification procedures.
- Compliance Officer.
- Monitoring Transactions.
- Risk Assessment
- VERIFICATION PROCEDURES
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Company establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks. Company uses KYC&AML-service provider, Shufti Pro company, according to the list and demands stated at: http://shuftipro.com/documents-we-verify and http://shuftipro.com/how-it-works.
Company’s identity verification procedure requires the User to provide Company with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Company reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
Company will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Company reserves the right to investigate certain Users who have been determined to be risky or suspicious, especially who use Website, Platform for the cryptocurrency storage purposes (wallet).
Company reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Company reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past
Once the User’s identity has been verified, Company is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
- COMPLIANCE OFFICER
The Compliance Officer is a person, duly authorized by Company, whose duty is to ensure the effective implementation and enforcement of the Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Company’s anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users’ identification information.
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
- Monitoring transactions and investigating any significant deviations from normal activity.
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly.
- Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
- MONITORING TRANSACTIONS
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Company relies on data analysis as a risk-assessment and suspicion detection tool. Company’s performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
- Case and document management.
With regard to the Policy, Company will monitor all transactions of selling and buying cryptocurrency between Users with Website, Platform and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when Company has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
- RISK ASSESSMENT
Company, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Company is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
Crypto Technologies LTD, registered in the Republic of Seychelles, company No: 215792, registered office is located at: Suite 1, Second Floor, Sound & Vision House, Francis Rachel Str., Victoria, Mahe, Seychelles.