AML Policy

Anti-money laundering policy

Anti-money laundering policy (hereinafter – “AML/ KYC Policy”) is meant for prevention and reduction of possible risks of the Company to be involved into any criminal activities.
In accordance with international and national regulations, the Company implements effective internal procedures and mechanisms for preventing money laundry, terrorism financing, drug and human trafficking, spread of mass destruction weapons, corruption, and bribery; and responding in case of any form of suspicious activities on the part of its Users.
AML/KYC Policy involves procedure of Verification, Transaction Monitoring, and Risk Assessment. Customer Due Diligence (CDD) is one of international standards of illegal activity prevention. With this purpose, the Company implements verification procedures in compliance with strict anti-money laundering standards.
The personal identification procedure of the Company requires that the User provide the Company with reliable, independent initial documents, data, or information (for instance, national ID card, international ID, bank statement). For such purposes, the Company reserves the right to collect the User’s identification information to observe the AML/KYC Policy.
The Company will take actions to verify identity of documents and information provided by the User. All legal methods for double verification of the identification information will be applied, and the Company reserves the right to investigate cases of particular Users, whose personalities are determined to be dangerous or suspicious.
The Company reserves the right to verify the user’s identity on a permanent basis, especially when his identification information has been modified or his activities appeared to be suspicious (unusual for a particular User). Besides, the Company reserves the right to request valid documents from the User, even if they have been verified before.
Information on the User’s identification will be collected, stored, jointly used and protected in strict compliance with the Company’s Privacy Policy and corresponding rules.
After the User’s identity authentication, the Company may disclaim potential legal responsibility in the situations when the Company’s services are used for criminal activities.
The Users, who are going to use payment cards for the Services use, shall pass the card verification in accordance with the instructions available at the Company’s website.

The Company provides for efficient implementation and observance of the AML/KYC Policy including but not limited to the following methods:

• Collection of the users’ identification information.
• Establishment and update of internal policies and procedures for completion, review, submission, and storage of all reports and records required in accordance with applicable laws and rules.
• Transaction monitoring and investigation of any substantial violations from normal activities.
• Regular update of risk assessment.
• Provision of law enforcement authorities with the information required in accordance with applicable laws and rules.
With regard to the AML/KYC Policy, the Company will control all transactions and reserves the right to:

• request the Users to provide any additional information and documents in case of suspicious transactions;
• suspend or terminate the User’s account if the Company reasonably suspects that the User is involved in criminal activities.

The above list is not comprehensive, and the Company will daily monitor the Users’ transactions in order to determine whether they should be considered suspicious or fair.
In compliance with international requirements, the Company applies the risk assessment practice to respond money laundering and terrorism financing. By using the risk assessment practice to respond money laundering, the Company ensures comparability of measures for money laundering and terrorism financing prevention or reduction to the assessed risks.