Anti-Money Laundering (AML) & “Know Your Customer” (KYC) Policy


Last update: May, 30th 2017

Introduction

The Company’s Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate potential risks of the Company being involved in any kind of illegal activity.

Both international and local regulations require the Company to implement effective internal mechanisms and procedures 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 the CDD, the Company establishes its own verification mechanisms and procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification

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

The Company will take the necessary steps to validate the authenticity of documents and the information provided by the Users. Every legal method for verifying identification information will be used and the Company reserves the right to investigate certain Users who have been determined to be risky or suspicious.

The Company reserves the right to verify User’s identity on an on-going basis. Users will be reviewed when their identification information recently changed or their activity seems to be suspicious (e.g. unusual for the specified User). In addition, the Company 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 Company’s Privacy Policy and related regulations.

Once the User’s identity has been verified, the Company will be 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 Company’s Services have to pass card verification in accordance with instructions available on the Company’s 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, 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:

  1. 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;
  2. Case and document management.

Regarding the AML/KYC Policy, the Company will monitor all transactions and it reserves the right to:

  1. ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
  2. request the User to provide any additional information and documents in case of suspicious transactions;
  3. suspend or terminate User’s Account when the Company has reasonably 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 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

In accordance with the international requirements, the Company 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.