Anti-Money Laundering and Know Your Customer Policy

INTRODUCTION

Wallet and Payments OÜ (hereinafter referred as “The Company”) Anti-Money Laundering and Know Your Customer Policy (AML-KCY Policy) is designed to prevent money laundering by meeting the Estonian AML/CFT legislation obligations including the need to have adequate systems and controls to mitigate the risk of being used to promote financial crime. The Company reserves the right to refuse registration to persons from jurisdictions that do not meet international AML-CFT standards.

Money laundering is a process, where money derived from illegal sources are introduced into the legal circulation. The main task of a person involved in the money laundering is a transformation of money into money or other financial instruments to hide as many traces of such illegal operation as possible. The Company takes all possible measures to prevent precedents where any of its customers can use the provided services for similar purposes.

The Company adheres to the following policy in the field of counteracting the legalization of proceeds from crime and the financing of terrorism by taking into account the concerns expressed by regulators of many countries, concerning the potential possibility of using crypto assets for illegal purposes, in particular, for the legalization of proceeds from crime and recognizing complete anonymity in the transactions of money transfers and purchase-sale of crypto assets, which contradicts the interests of its customers.

To monitor compliance with the legislation, the Company develops AML/KYC procedures, which are mandatory for compliance by all employees of the Company and policy-defining interactions with persons who enter into an agreement with the Company and become clients of the Company (hereinafter referred to as the “Customers”).

In order to protect the funds of our Customers and to ensure compliance with the world trade standards the Company works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities:

  • Directive (EU) 2015/849/ЕU (with changes) of the European Parliament and of the Council of 20 May 2015;

  • Money Laundering and Terrorist Financing Prevention Act;

  • Payment Institutions and E-money Institutions Act;

  • other (if necessary).

The Company compliance shall ensure that the Company’s activities comply with international standards of Anti-Money Laundering Policy and all documents provided by the Customers are relevant and comply with the requirements of the law.

PLEASE READ THIS POLICY CAREFULLY BY ENTERING OR USING THE COMPANY'S SERVICE, YOU CONFIRM THAT YOU READ, UNDERSTAND AND AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS. IF YOU DO NOT AGREE TO THESE TERMS, GO TO THIS PAGE AND DO NOT GET OR USE THE SERVICES OF THE COMPANY.

 

All questions concerning this Policy please send to the address: Harju maakond, Tallinn, Lasnamäe linnaosa, Peterburi tee 47, 11415.

2. GOALS AND OBJECTIVES

The goal of this Policy is to comply with relevant legislation and normative legal acts, and demonstrate that the Company takes seriously any attempt to use its services for illegal and unlawful purposes.

Legislation obliges the Company to take the necessary measures to prevent and identify cases of money laundering. The Company, in its turn, makes sure that the internal guidelines, procedures and controls used by competent specialists properly and always comply with the latest requirements and innovations.

The Company applies the verification procedure for all new Customers and can not start business relations until the identification of a new Customer is successfully confirmed.

3. INTERNAL RULES AND REGULATIONS

Regulations require the Company to have:

  • Policies and procedures to prevent them from being used by money launderers;

  • Employees trained in these procedures and in anti-money laundering law;

  • Checks and controls to ensure that the policies and procedures are working;

  • Have internal and external measures in place for the disclosure procedures for suspicious transactions.

To comply with the policy of counteracting the legalization and laundering of illegal funds, the Company performs the following:

  • Identification of customers (both individuals and legal entities);

  • Saving the history of Customers’ transactions for at least for 5 (five) years;

  • Establishing the criteria for questionable and unusual transactions as well as methods for determinating them;

  • Monitoring and verification of suspicious transactions and their compliance with the criteria of questionable and unusual transactions;

  • Suspension of suspicious transactions to ascertain the circumstances and to carry out the investigation with the subsequent return of suspicious funds back to the sender account;

  • Waving of any obligations to the Customer if the company becomes aware that the Customer committed in any way to use the Company’s service to carry out illegal activities, including the legalization of proceeds from crime and the financing of terrorism;

  • Providing available information about the Customer and his transactions to the law enforcement authorities on the appropriate official request.

In case the Company specialists in the course of monitoring will find out that any of the Customers use the Company’s services for money laundering, the company reserves the right to block the Customer’s account and all stored funds until the end of the internal investigation.

The Company also reserves the right to provide this information to the police, the authorized regulator or any other control body without the consent of the Customer.

According to the existing standards and requirements the Company has implemented the following measures:

  • Approved the position of responsible officer (Compliance Officer) for reporting on the suspicious activities related to money laundering;

  • Implemented a mandatory training program for all company employees on methods and measures to counter money laundering;

  • Established a risk-based approach to the assessment and management of financial risk in business related to money laundering;

  • Implemented and applied in practice a prudent approach to Customers, based on risk assessment, personal identification and customer address verification according to the principles of “Know Your Customer” (KYC), providing additional thorough checks of “suspicious” customers, which the Company determines at its sole discretion during the monitoring and verification of operations;

  • Implemented a system for monitoring operations (automatic and, if necessary, manual) using systems and methods based on risk assessment of for continuous tracking of current customer activity to prevent the use of the company’s services for illegal purposes;

  • Adheres to a special procedure for the detection and reporting of suspicious activities or suspicious transactions when using the company services.

4. CUSTOMER IDENTIFICATION

Based on Money Laundering and Terrorist Financing Prevention Act we have to identify and verify any person who enters in a business relationship with us or who has an occasional transaction, including any person acting on their behalf and any beneficial owners.

Identification required for all customers who have registered of an account (personal or corporate) at https://Credits.com, regardless of the added (deposit) amount or send (withdrawal) amount available on the balance to a bank account or any other payment system. The identification procedure is a prerequisite for any financial and exchange operations, until completion of the identification procedure, Customer account is unverified and has restrictions for making financial transactions and transfers.

The Customer understands that the name, address, telephone number and any other personal information, including documents (such as passport, national identity card, bank account statement, telephone bills, electricity bills or other utility bills) must be true and valid on the upload date (the validity of the passport, national ID is according to the period indicated in them or according to the legislation of the issuing country; a bank statement, telephone bills, electricity bills or other utility bills must be issued no later than a 3 months before the date of their provision ).

For individuals:

  • Full name;

  • Gender (male/female);

  • Date and place of birth;

  • Place of residence (thereby identifying risks associated with countries, geographic areas or jurisdictions);

  • Contact phone and email.

The verification process is performed once and can be re-initiated only when the Customer’s registration data or documents are changed. After assigning to the Customer “Verified” status, the re-submission of the verification documents is not required, with the exception of cases where the Company and / or the government authority suspect that the Client has violated applicable law.

To prevent compromising of Customer’s personal data, documents uploading and data entry is done through a secure interface in the Customer’s local area (secure log-in) using encrypted protocol.

5. REQUIREMENTS FOR THE DOCUMENTS

Under this Policy, any customer who decides to use the services of the Company also agrees to provide identification and verification documents that confirm identity, address and financial status, among them:

For individuals:

  • Identity document: a color copy of the passport (the first, second page with photos, as well as a page with registration data), or a color copy of the document that is proper for confirming the identity of the Customer according to the legislation of the country of which the Customer is a resident;

  • Copy of the utility bill or bank statement for confirmation of the Customer’s residence (the document shall not be older than 3 months).

The Company does not accept the following types of documents as proof of address: phone bill (statement), driving license, couriers receipts, documents issued by the pension fund or insurance companies, the invoices from the shops and other companies in the area of trade and service, credit/debit card statements issued by a store or another bank agent.

In case if customer wants to make payment using credit and debit cards of international payment systems Visa, MasterCard and others, the Company will require him to pass the card verification process by providing a scan/photo of the front and back sides of the card (for security purposes, it is allowed to partially hide the card number on the front side and validation code CVV2/CVC2 on the backside) or by verifying the payment amount in accordance with the instructions in the personal account.

Copies of supporting documents must be submitted in color, at high resolution (at least 1920×1080), JPEG, JPG, GIF, PDF, max. capacity of each document should not exceed 10 Mb. The Company reserves the right to decline the documents that do not correspond to the above requirements.

6. ADDITIONAL REQUIREMENTS

According to the existing standards and requirements in anti-money laundering the Company reserves the right at any time to request the customer to present additional documents or any additional information needed for identification.

The Company can freeze (block) the account of any Customer in case of suspicion of fraudulent activity, which may be related to the money laundering, or in case of the customer refuses to provide the requested identification documents.

If the Customer refuses to provide the requested documents and information as a response to a request from the Company without proper justification, the Company will not start a contractual relationship with this Customer, and may also notify this fact to the authorized regulator. This can lead to the suspicion that the Customer is engaged in money laundering and the financing of terrorism.

If the account has been blocked and further investigation and interaction with the Customer cause problems that can not be resolved, the Company can close the account and return all funds from the balance to the source from which they were received.

7. ENHANCED DUE DILIGENCE

Extended due diligence is carried out with respect to politically exposed persons, and/or in the presence of the signs specified in the internal Company’s policy and procedures.

If the Company has assessed that the business relationship with the Customer poses a high risk it will apply the following additional measures:

  • Additional information on the Customer;

  • Additional information about the reasons for choosing a company and on the intended nature of the business relationship;

  • Information on the source of funds or source of wealth of the Customer;

  • Information on the volume of planned transactions and transfers;

  • Additional information on individuals with ownership or control over the account, such as beneficial owners, signatories, guarantors;

  • Information about the reasons for the intended or performed transactions;

  • Financial statements and banking references;

  • Information on the availability of financial assets or property;

  • Enhanced monitoring of the relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further explanation;

  • Requiring that the first payment be carried out through an account in the customer’s name with a bank subject to similar customer due diligence standards;

  • Introducing enhanced reporting mechanisms/systematic reporting for financial transactions with individuals/legal entities.

The Company will conduct ongoing Customer due diligence and account monitoring for all business relationships with Customers. It particularly involves regularly reviewing and refreshing Company’s view of what its Customers are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Customer. It can also include anything that appears to be a material change in the nature or purpose of the Customer’s business relationship with the Company.

8. TRANSACTIONS MONITORING

The Customer is known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, the Company relies on data analysis as a risk-assessment and suspicion detection tool. The Company performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  • Daily check of Customers against recognized “blacklists” (e.g. OFAC), aggregating transfers by multiple data points, placing Customers 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 AML-KYC Policy, the Company will monitor all transactions 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 Customer to provide any additional information and documents in case of suspicious transactions;

  • Suspend or terminate Customer’s account when the Company has reasonable suspicion that such Customer engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor Customer’s 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 conscientious.

9. RISK ASSESSMENT

The 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, the 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.

10. Changes to this policy

The company has the right to make changes to this Policy. When changing the current version, the date of the last update the new Policy comes into force from the day of its publication, unless otherwise provided in the new Policy.

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