Anti-Money Laundering Policy

Last update: August 2020

Anti-Money Laundering Policy (hereinafter - the “AML Policy”) is designated to prevent and mitigate possible risks of being involved in any kind of illegal activity. Both international and local regulations require to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from Participants.

1. Verification procedures

This procedures is executed with collaboration with Veriff; Estonia in EU based Verification professional company(hereinafter ”We”).

We require the Participant to provide with reliable, independent source documents, data or information (e.g., national ID, international passport, driver’s license). For such purposes We reserves the right to collect Participant’s identification information for the AML Policy purposes.

We will take steps to confirm the authenticity of documents and information provided by the Participants. All legal methods for double-checking identification information will be used and We reserves the right to investigate certain Participants who have been determined to be risky or suspicious.

We reserve the right to verify Participant’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious. In addition, we reserve the right to request up-to-date documents from the Participants, even though they have passed identity verification in the past.

Participant’s identification information will be collected, stored, shared and protected strictly in accordance with the Privacy Policy and related regulations.

Once the User’s identity has been verified, we are able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

2. Monitoring Transactions

The Participants are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, we rely on data analysis as a risk-assessment and suspicion detection tool:

1) Check of Users against recognized “black lists” (e.g. OFAC);

2) Case and document management.

We will monitor all transactions and we reserve the right to:

The above list is not exhaustive, and we will monitor Participants’ 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.

3. Risk Assessment

We have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are 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.