The purpose of the Anti-money Laundering and Counter Terrorism Financing, Know your customer, Sanctions and Countries Policy (AML/CTF & KYC & SANCTIONS & COUNTRY POLICY (hereinafter referred to as the "Policy" or "AML/KYC Policy") is to establish a system of controls and mechanisms to prevent involvement of the Any.Money and/or services of Any.Money in money laundering and/or terrorist financing activities and/or violation of the established sanctions restrictions, preserving and maintaining the reputation of Any.Money when interacting with customers, counterparties, and representatives of authorized bodies.
This Policy describes the main standards, principles, rules, and approaches used by Any.Money to study its customers and counterparties, conduct activities to manage money laundering and terrorist financing risks, sanctions, and countries.
Internal documents on AML/CTF risk management and KYC/CDD procedures are developed by the Company additionally and are internal documents of the Company with limited access. Such documents comply with this Policy.
The Company ensures compliance with the requirements of this Policy and applicable law by all employees of the Company.
Definitions Capitalized terms in this Policy have the meanings as follows:
Any.Money means the Any.Money website and/or the company providing the services on the Any.Money website.
Prohibited Conduct means any illegal conduct that includes fraud, corruption, money laundering, collusion, terrorist financing, and any other criminal conduct.
Fraud means the use of deception for the purpose of pursuing personal interests and damaging the interests of Users and/or Any.Money.
Scam means a method of deception, fraud in order to obtain money from Internet users, may include hiding information or providing incorrect information in order to extort money, property, and inheritance from victims.
Corruption means offering, giving, receiving, or soliciting, directly or indirectly, anything of value that could improperly influence the actions of another party.
Money Laundering means a scheme of financial transactions, the purpose of which is to conceal the identity, source, and destination of illegally obtained money or to finance illegal activities.
Anti-Money Laundering (AML) means a set of measures and procedures aimed at detecting and/or preventing the use of the Any.Money company/website and/or services provided by Any.Money for money laundering purposes.
Counter-Terrorist Financing (CTF) means a set of measures and procedures aimed at detecting and/or preventing the use of the Any.Money company/website and/or services provided by Any.Money for the purposes of financing terrorism.
Sanctions mean economic sanctions that are commercial and financial sanctions applied by one or more countries against targeted self-governing states, groups, or individuals.
Red Flags mean a warning or indicator suggesting the presence of a potential problem or threat with the Customer's operation that passes through the Company and/or the Services of the Company.
Collusion means an agreement between two or more parties to achieve an improper purpose, including improperly influencing the actions of the other party.
Terrorist Financing means the provision or collection of funds by any means, directly or indirectly, with the intention of using them or on the condition that they be used in whole or in part to carry out any of the crimes related to terrorism.
Criminal Conduct means a crime in any part of the world or what would qualify as a crime in any part of the world if it happened there.
Know Your Customer (KYC) means a set of measures and procedures aimed at obtaining information about the customer and their activities in order to manage the risks of the Company.
Customer Due Diligence means verification of data/information about the customer and other checks related to the study of the customer and their activities, with the aim of a comprehensive risk assessment of the customer when accepting them for service and during their service.
Politically Exposed Person (PEP) means an individual who plays a prominent public role within a country or internationally.
Regulatory Requirements mean any applicable law, statute, regulation, order, judgment, decision, recommendation, rule, policy (including but not limited to KYC/AML/CTF Policy) or guidance enacted or issued by parliament, government, or any competent court or authority, or any payment system (including, but not limited to, bank payment systems, card payment systems such as Visa, MasterCard, or any other payment, clearing or settlement system, or similar agreement that is used to provide the Services.
1.1. In order to provide an appropriate and timely level of services to customers, the Company must comply with the requirements contained in domestic and international laws on the prevention of money laundering and terrorist financing, as well as the requirements of other laws and regulations to the extent that they are related to the activities of the Company.
1.2. For the implementation of the procedures stipulated by this Policy, the Company shall develop and implement an internal system for assessing the level of risks of the customer and their transactions, determine the minimum necessary set of requirements, procedures, mechanisms, reports, systems, and controls for managing the Company's risks. More stringent procedures apply for high-risk customers and transactions.
1.3. The Company may introduce changes and supplements to the Policy at its own discretion (as new risks are detected and identified, new products/services and changes in applicable law are introduced) and will monitor compliance with its provisions and requirements.
2.1. 2.1. The Company conducts Know Your Customer (KYC) verification procedures to avoid the risk of being held liable for the violation of applicable law and to protect itself from the Customer’s attempts to use the Company and/or its services and/or the service to carry out illegal actions, including those aimed at the financing of terrorism or for the purpose of money laundering.
2.2. As part of the KYC procedures, the Company shall:
2.2.1. establish the identity of its customer – it shall study its Customer when establishing relationships and clarify information about them during their service.
The Company shall perform identification procedures related to the Customer:
a) when establishing a relationship;
b) annually for high-risk customers, once every two years for medium-risk customers, once every three years for low-risk customers;
2.2.2. study the nature of the customer's activities (the main goal is to make sure that the source of the customer's funds is legal).
- examine and evaluate transactions of Customers in order to assess the money laundering risks associated with this Customer, in order to monitor the activities of the Customer;
2.2.3. collect and store information about Customers, the results of their study, as well as material facts relating to Customers, potential Customers, and their transactions.
2.3. In order to identify Customers, the Company shall request the documents as follows:
2.3.1. For individuals (depending on the type of product/access to products and services):
- nickname in the messenger (telegram);
- phone number;
- e-mail address.
- internal and/or foreign passport;
- identity card, ID card;
- driver license.
- a copy of the utility bill;
- a copy of the phone bill;
- a copy of the electricity bill;
- statement from the bank.
2.4. Customer Due Diligence.
In the process of studying Customers, the Company can undertake three levels of verification:
- Simplified Due Diligence (“SDD”) are situations where the risk of money laundering or terrorist financing is low and full due diligence is not required. For example, accounts with low turnover and transaction amounts.
- Basic Customer Due Diligence ("CDD") is the information obtained from all customers to verify the identity of the customer and assess the risks associated with that customer.
- Enhanced Due Diligence (“EDD”) is additional information collected about higher-risk customers to provide a deeper understanding of the activities of such customers in order to mitigate their risks.
2.5. Establishment of relations with PEP takes place only upon agreement with the Company's Management. Such Customers are assigned high risk and subject to the EDD procedure.
2.6. After carrying out identification procedures related to the Customers, the Company shall store the information received in the file of this Customer.
2.8. The Company shall carefully store the Customer's files, including statements, transaction reports, receipts, notes, internal correspondence, and any other documents related to the customer, in electronic format within the time required in case they can be requested by the underwriting teams in the respective acquiring banks/processors used by the Customer, payment agents involved in transactions, law enforcement agencies and/or other state-authorized bodies, etc.
2.9. The Company has the right to suspend an Account associated with suspicious activity (including but not limited to activities that can be defined as money laundering, terrorist financing, scam, etc.) and ask the owner of such an Account to go through an in-depth KYC procedure (request additional required documents). If the Customer does not provide the necessary documents or the provided documents are not enough to remove suspicion of suspicious activity, the Company has the right to suspend servicing the customer's account/transactions temporarily or indefinitely, including until the account is completely blocked and all assets are blocked.
3.1. Any financial transaction that may be related to money laundering, terrorist financing, violation of sanctions restrictions, scam is considered suspicious.
3.2. The Company independently develops and implements a mechanism for identifying such transactions, a system and definitions of red flags, criteria for identifying risks. The basis for determining that a particular transaction is suspicious may be personal observations and experience of the Company's employees, information obtained during KYC procedures, information obtained using specialized analytical programs and/or systems, etc.
3.3. The Company shall regularly monitor the transactional activity of its Customers, update the systems and Red flags criteria used to detect suspicious activities, and implement international best practices for detecting suspicious activities.
3.4. In accordance with applicable laws in force and the requirements of competent international organizations, the Company may, where appropriate, and without the obligation obtain the approval or notification of the Customer, notify the regulatory and/or law enforcement authorities of any suspicious transactions, as well as provide the necessary information in response to requests from such organizations.
3.5. When conducting a study of Customers and analyzing their transactions, the Company uses the lists as follows:
- sanctioned persons, known terrorists and/or terrorist organizations, or persons suspected of terrorist activities, published by local authorities and international organizations such as OFAC (Office of Foreign Assets Control), EU, Ukraine, UN, etc.,
- jurisdictions that do not provide an adequate level of anti-money laundering procedures in accordance with FATF policies, as well as countries that are subject to OFAC, EU, Ukraine, UN, etc. sanctions,
- high-risk countries, Annex 1, to determine if the Company's Customer or potential Customer and/or the country/jurisdiction of such a Customer is included in the above lists, cooperation with which is prohibited or undesirable.
3.6. The Company shall constantly conduct due diligence procedures in relation to its Customers and carefully check the transactions they conduct to ensure that these transactions are compatible with the Company's knowledge of its Customers, their business, and their source of income, if necessary.
3.7. The Company shall not establish relationships with Customers who are included in the sanctions lists or registered/located in the territories/jurisdictions specified in para. 3.5. or are under the control of such persons.
3.8. If the Customer is identified as an unacceptably high risk, the Company may refuse further service to such a Customer.
4.1. To perform some of its business functions, the Company may engage third-party service providers or interact with counterparties. The Company makes every possible effort to study such a service provider/counterparty and its activities, and to determine, as far as possible, its reputation (whether there are any initiated investigations and claims against any such third-party service providers). The Company also determines whether a third-party provider has obtained all necessary licenses, permits, and approvals before establishing a business relationship with such a third-party service provider.
4.2. The Company does not establish relations with a service provider and/or counterparty that is included in the sanctions lists or registered/located in the territories/jurisdictions specified in para. 3.5. or which are under the control of such persons.
5.1. The Company takes all possible measures to train employees in order to prevent the Company from being involved in actions aimed at using the Company and/or the Services of the Company for the purpose of money laundering, terrorist financing, scam or violation of established sanctions restrictions.
5.2. The Company can conduct employee training in the form of electronic courses, online webinars, face-to-face seminars and in any other way that will allow conveying the necessary information to employees and, if necessary, testing the knowledge gained.
5.3. With regard to its own personnel, the Company takes all possible measures to carefully analyze all candidates for a job in order to determine whether the activity and/or reputation of a new employee falls into a category that is subject to or bears the risk of money laundering.
The Company develops and implements internal reporting that provides timely information about the Company's risks and their management. If an employee of the Company becomes aware of activities that fall under the restrictions specified in the Policy, such an employee must immediately notify about such an event and provide all the necessary/available information to his/her manager and/or authorized unit (compliance) and/or top management of the Company.
7.1. By using the Services of the Company, you warrant that you do not intend to engage in any of the prohibited activities described herein; furthermore, you consent to any checks related to the conduct of an investigation in accordance with the Anti-Fraud Policy and agree to cooperate fully and promptly with the anti-fraud commissioner in such an investigation. Failure to cooperate or failure to provide the required information/documents may result in the suspension of your service or the complete refusal of further service.
8.1. This program is approved in the manner prescribed by Any.Money and approved by the Management of Any.Money.
8.2. This Policy comes into force upon approval and/or publication on the Any.Money website.