AML/KYC Policy

This document outlines the standards of the Anti-Money Laundering (AML) and Know Your Customer (KYC) policies, describing the methods used to prevent money laundering activities when dealing with our clients.

The purpose of the AML/KYC policy is to prevent the intentional or unintentional use of {APP_NAME:string} by criminal elements for money laundering activities. The policy also requires reasonable efforts to identify the true identity and beneficial owner of accounts, the source of funds, the nature of the client's business, the legitimacy of account transactions related to the client's business, and more. This helps us effectively analyze risks.

We aim to protect our clients from fraudulent activities in the cryptocurrency space. {APP_NAME:string} follows a consistent approach in implementing the latest recommendations and revised guidelines of FATF, the European Parliament, and financial industry regulators as a whole. Our compliance policy is aimed at identifying funds associated with illegal activities and protecting our clients' funds, who may fall victim to hacks, ransomware, and other malicious software. The current toolkit for combating money laundering and its consequences consists of regulatory acts combined with the latest developments in real-time suspicious transaction tracking software.

Our AML/KYC policy, procedures, and internal controls are designed to ensure compliance with all applicable regulations and will be regularly reviewed and updated to comply with relevant policies, procedures, and internal controls in light of changes in regulations.

The policy consists of the following sections:

1. Customer Identification Procedure (CIP)
2. Documentation Keeping
3. Compliance Officer for Anti-Money Laundering Compliance Requirements
4. Transaction Monitoring
5. Cooperation with Law Enforcement Authorities

Customer Identification Procedure (CIP)

CIP is applied to transactions that our risk assessment system deems suspicious. We gather specific identification information about each client undergoing CIP. The identification procedure includes the following steps:

• Request for Identification Data.
  1. Full name (for individuals);
  2. Date of birth (for individuals);
  3. Residential address (for individuals) or the primary place of business, office, or other physical location;
  4. For individuals only: a valid government-issued identification document confirming citizenship or place of residence and containing a photograph, such as a driver license or passport;
  5. For legal entities: documents confirming the existence of the legal entity, such as a certified founding agreement, business license, partnership agreement, or other verifying document.
• Verification of Received Information for Originality and Accuracy

  Clients must ensure that the information provided is accurate, complete, and kept up-to-date. If there are grounds to believe that the information provided by the client is incorrect, false, outdated, or incomplete, we reserve the right to send the client a notice requesting correction and supplementation of identification information. Depending on the circumstances, {APP_NAME:string} may blacklist the existing account and terminate services for that client.

• Information Verification

  We will continue to verify the information collected to determine the true identities of our clients using procedures based on the risk assessment of our service provider, Sum & Substance Ltd, which verifies the completeness and accuracy of the information obtained for client identification. Checks are also conducted to ascertain whether a client appears on lists of individuals involved in criminal activities and other lists of sanctioned individuals.

  We will verify the information within a reasonable timeframe, depending on the nature of the account and the level of risk associated with transactions. We may request additional time for verification, restrict transactions, and the client's account if we discover suspicious information indicating potential money laundering, terrorist financing, or other suspicious activities. We may file a Suspicious Activity Report(SAR) or Suspicious Transaction Report(STR) in accordance with the legal framework if we identify suspicious information.

• Client Notification

  We inform clients that their transactions may be subject to AML/KYC checks. This information is detailed in our Terms of Use, and each client is obligated to review these Terms before initiating transactions.

• Checks Conducted by Third Parties

  We may rely on CIP checks conducted by an exchange or trading platform concerning any client when deemed reasonable by the exchange or trading platform. The client will also be notified of the circumstances surrounding such checks.

Documentation Keeping

We will document our verification, including all identifying information provided by the client, the methods used, verification results, and the resolution of any discrepancies identified during the verification process.

According to Sum Substance documentation, all client data obtained during the KYC procedure is encrypted and stored on Amazon servers, in compliance with GDPR regulations, located in the European Zone.

All documentation can be provided to competent authorities upon request.

AML Compliance Officer

The Anti-Money Laundering (AML) Compliance Officer is an authorized {APP_NAME:string} employee responsible for implementing and effectively monitoring the application of the AML/KYC policy. The AML Compliance Officer oversees and upgrades all aspects of {APP_NAME:string}'s activities related to combating money laundering and terrorist financing.

Contact with the AML Compliance Officer regarding this Policy can be made through [email protected]

Transaction Monitoring

Continuous monitoring is an essential element of effective KYC procedures. It allows us to differentiate between a client normal activities and suspicious activities that require attention.

Cooperation with Law Enforcement Authorities

We obtain and store information about senders and recipients when exchanging cryptocurrencies and provide it to the relevant authorities upon an official request.