Introduction
The CryptoUnity Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designed to prevent and mitigate possible risks of CryptoUnity being involved in any kind of illegal activity.
Both international and local regulations require CryptoUnity 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 its Users.
The AML/KYC Policy covers the following matters:
- Verification procedures
- Sanctions and PEP lists screening
- Compliance Officer
- Monitoring Transactions
- Risk Assessment
1. Verification Procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, CryptoUnity establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
1.1. Identity Verification
CryptoUnity’s identity verification procedure requires the User to provide CryptoUnity with reliable, independent source documents, data, or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, CryptoUnity reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
CryptoUnity 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 CryptoUnity reserves the right to investigate certain Users who have been determined to be risky or suspicious.
CryptoUnity reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has been changed or their activity seems suspicious (unusual for the particular User). In addition, CryptoUnity reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared, and protected strictly in accordance with the CryptoUnity’s Privacy Policy and related regulations.
Once the User’s identity has been verified, CryptoUnity is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1.2. Card Verification
The Users who intend to use payment cards in connection with the CryptoUnity’s Services have to pass card verification in accordance with instructions available on the CryptoUnity’s Site.
2. Sanctions and PEP Lists Screening
CryptoUnity screens applicants against recognized Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
- At the onboarding stage when the user is submitting the application;
- On each anti-fraud and AML alert manually by the Compliance Officer;
- Monthly by running automatically with a script to re-check all databases of customers.
For the screening process, CryptoUnity uses data provided by third-party services integrated into the proprietary software for manual confirmation.
3. Compliance Officer
The Compliance Officer is the person, duly authorized by CryptoUnity, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of CryptoUnity’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.
- 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 agencies involved in the prevention of money laundering, terrorist financing, and other illegal activities.
4. Monitoring Transactions
Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, CryptoUnity relies on data analysis as a risk-assessment and suspicion detection tool. CryptoUnity performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Daily 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 AML/KYC Policy, CryptoUnity will monitor all transactions and 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 the User’s Account when CryptoUnity has reasonable 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 to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
5. Risk Assessment
CryptoUnity, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, CryptoUnity can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This allows resources to be allocated in the most efficient ways, directing attention to the greatest risks.
