AML

Introduction

Crypterum.com Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML/KYC Policy") is designated to prevent and mitigate possible risks of Crypterum.com being involved in any kind of illegal activity.

Both international and local regulations require Crypterum.com 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.

AML/KYC Policy covers the following matters:

  1. Verification procedures.
  2. Monitoring Transactions.
  3. Risk Assessment.

1. Verification procedures

One of the international standards for preventing illegal activity is customer due diligence ("CDD"). According to CDD, Crypterum.com establishes its own verification procedures within the standards of anti-money laundering and "Know Your Customer" frameworks.

1.1. Identity verification

Crypterum.com's identity verification procedure requires the User to provide Crypterum.com with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Crypterum.com reserves the right to collect User's identification information for the AML/KYC Policy purposes.

Crypterum.com 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 Crypterum.com reserves the right to investigate certain Users who have been determined to be risky or suspicious.

User verification process includes, but not limited to providing these documents proving his or her identity:

For natural persons:

  1. To confirm the User’s identity the User should provide one of the following documents:
    • A civil passport;
    • An international passport;
    • ID card.
  2. To confirm the User’s residential address the User should provide one of the following documents:
    • Bank statement where clearly seen the address of your actual residence;
    • Utility bill where clearly seen the address of your actual residence;
    • Taxation documents where clearly seen the address of your actual residence;
    • A document confirming your residence issued by local authorities where clearly seen the address of your actual residence.

For corporate clients:

  1. To confirm the User’s identity the User should provide one of the following documents:
    • A civil passport of a director;
    • An international passport of a director;
    • ID card of a director;
  2. To confirm the User’s address the User should provide one of the following documents:
    • Bank statement where clearly seen the address of actual residence of a director;
    • Utility bill where clearly seen the address of actual residence of a director;
    • Taxation documents where clearly seen the address of actual residence of a director;
    • A document confirming your residence issued by local authorities where clearly seen the address of actual residence of a director.
  3. To confirm that the User is an authorized representative of an entity the User should provide all of the following documents:
    • A document confirming a company’s residential address;
    • А document of incorporation;
    • An order on the appointment of the director;
    • A scanned copy or a photo of a letter of a decision to work with Crypterum.com.
  4. Ultimate beneficial owner information and Ultimate beneficial owner’s KYC documentations:
    • A civil passport of an Ultimate beneficial owner;
    • An international passport of an Ultimate beneficial owner;
    • ID card of an Ultimate beneficial owner;
    • Prove of residence document.

Ultimate beneficial owner means:

‘Ultimate beneficial owner’, according to Cyprus legislation, means the natural person or natural persons who ultimately own or control the User’s Account and/or the natural person on whose behalf a transactions or activity is being conducted. The beneficial owner shall at least include:

  1. in the case of corporate entities:
    • the natural person or natural persons who ultimately owns or controls a legal entity through direct or indirect ownership or control over a sufficient percentage of the shares or voting rights in that legal entity, including through bearer share holdings, of a percentage of 10 % plus one share;
    • the natural person or natural persons who otherwise exercise control over the management and direction of a legal entity.
  2. in the case of legal entities, such as foundations and legal arrangements, such as trusts, which administer and distribute funds:
    • where the future beneficiaries have already been determined, the natural person or natural persons who are the beneficiaries of 10 % or more of the property of a legal arrangement or entity;
    • where the individuals that benefit from the legal arrangement or entity have yet to be determined, the class of persons in whose main interest the legal arrangement or entity is set up or operates, the natural person or natural persons who exercise control over 10 % or more of the property of a legal arrangement or entity.
      Crypterum.com reserves the right to verify User's identity in an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Crypterum.com 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 Crypterum.com Privacy Policy and related regulations.

Once the User's identity has been verified, Crypterum.com 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 are intended to use payment cards in connection with the Crypterum.com Services have to pass card verification in accordance with instructions available on Crypterum.com Site.

2. Monitoring Transactions

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

With regard to the AML/KYC Policy, Crypterum.com will monitor all transactions and it reserves the right to:

  1. request the User to provide any additional information and documents in case of suspicious transactions;
  2. suspend or terminate User's Account when Crypterum.com has reasonable suspicion that such User engaged in illegal activity.

The above list is not exhaustive and the transactions will be monitored 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.

The User will not be able to create a Voucher using funds credited from online payment cards. The funds credited from online payment cards can be spent only on cryptocurrency or returned back to the same card.

3. Risk Assessment

Crypterum.com, 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, Crypterum.com 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.