Anti-Money Laundering / Know Your Client

This Anti-Money Laundering and Know Your Client Policy (hereinafter - the “Policy”) is designed to prevent and mitigate the risk of Walleteze OÜ being involved in any kind of illegal activity.

Walleteze OÜ implements effective internal procedures and instruments to prevent illegal transfer of assets, drugs, humans, organs and any other illegal trafficking, poaching, pornography, trade in arms, terrorism and crime financing, corruption, bribery and money laundering, and takes action in cases of suspicious activity by its Clients.

This Policy includes verification procedures, compliance officer, monitoring of transactions, risk assessment.

1. VERIFICATION OF CUSTOMERS
1.1. One of the international standards for preventing illegal activity is client due diligence. Walleteze OÜ has established its own verification procedures within the standards of “Know Your Client” frameworks.

1.2. The Walleteze OÜ identity verification procedure requires the Client to provide Walleteze OÜ with reliable, independent-source documents, data or information. Walleteze OÜ reserves the right to collect Clients’ identification information to meet the requirements of the Policy.

1.3. Walleteze OÜ will take steps to confirm the authenticity of documents and information provided by Clients. All legal methods for double-checking identification information will be used and Walleteze OÜ reserves the right to investigate certain Clients who match a higher risk profile or appear suspicious.

1.4. Walleteze OÜ reserves the right to review Clients’ proofs of identity on an on-going basis, especially where identification information has changed or activity appears suspicious / unusual for a particular Client. Walleteze OÜ can decide which traits / activities are deemed suspicious at its sole discretion.

1.5. Walleteze OÜ reserves the right to request up-to-date documents from the Clients, even if they have previously passed identity verification.

1.6. Clients’ identification information will be collected, stored, shared and protected strictly in accordance with the Walleteze OÜ Privacy Policy.

2. PAYMENT AND TRANSACTIONS PROCESSING
2.1. Walleteze OÜ strictly prohibits using the Services through anonymous proxy servers or other anonymising Internet connection.

2.2. In order to prevent potentially unlawful transactions, Walleteze OÜ requires the recipient of a payment to be the same person as the sender. Payments in favor of a third party are strictly prohibited.

2.3. Card funding options require 3D Secure processing.

3. COMPLIANCE OFFICER
3.1. The Compliance Officer is the person, duly authorized by Walleteze OÜ, whose duty it is to ensure the effective implementation and enforcement of the Policy. The Compliance Officer is obliged to have relevant education and specific knowledge and expertise in AML fundamental and practical issues.

3.2. It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including, but not limited to: collecting Clients’ identification information; establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under applicable laws and regulations; monitoring the transfer of assets and investigating any significant deviations from normal transfer activity; implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; and regularly updating risk assessment.

3.3. The Compliance Officer is entitled to interact with competent authorities involved in the prevention of all types of illegal activity.

4. MONITORING OF TRANSACTIONS
4.1. In order to prevent unlawful activity, Walleteze OÜ also uses internal automated systems for analyzing transactions and Clients’ behavior; blocking suspicious activity; setting limits on Clients’ transactions; observing the Know-Your-Client policy; and performing verification of the data provided by Clients by employing any available means. Walleteze OÜ analyses what Clients do on the platform and relies on analysis of that data as a risk-assessment and suspicion detection tool. Walleteze OÜ may perform a variety of compliance-related tasks, including capturing of data, filtering, record-keeping, investigation management, and reporting.

4.2. Walleteze OÜ uses block chain monitoring tools for Client deposit or withdrawal crypto-currency transactions exceeding the equivalent of 1,000 units of fiat currency.

4.3. Walleteze OÜ implements additional verifications and manual processing of withdrawal transactions exceeding the equivalent of 5,000 units of fiat currency.

4.4. Monitoring system functionalities include: aggregating transfers of assets by multiple data points, placing Clients on watch and service denial lists, opening cases for investigation where needed and sending internal сase and document management notices.

4.5. With regard to the Policy, Walleteze OÜ will monitor all transfers of assets and it reserves the right to: ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer; request the User to provide additional information and documentation for suspicious transfers of assets; suspend or terminate Clients’ Accounts where Walleteze OÜ has reasonable suspicion that such Clients are engaged in illegal activity.

4.6. Walleteze OÜ sets limits on withdrawals of funds initiated earlier than 3 (three) days after initial Account funding, or after changes in Clients’ account data, password recovery, password reset, or change of authorization method.

4.7. Use of the Services for purposes other than those provided for in the Terms and Conditions (in particular, for the deposit and withdrawal of funds in the absence of trading activity), may be deemed suspicious and are prohibited.

4.8. The above list is not exhaustive - Internal Control Specialists constantly monitor the Transactions of Clients to determine whether transactions should be treated as suspicious.

5. RISK ASSESSMENT
Walleteze OÜ, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. This enables Walleteze OÜ to ensure that measures aimed at preventing illegal activities are commensurate with identified risks. The principle involves directing resources in accordance with priorities so that the greatest risks receive the highest attention.