AML, KYC & CTF Policy

AML (Anti Money Laundering), KYC (Know Your Customer) & CTF (Counter Terrorist Financing) Policy

 

GENERAL

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions.

To comply international and local regulations, Coinnor.com implements 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 act in case of any form of suspicious activity from its Customers.

 

AML/KYC/CTF Policy covers the following matters:

 

1. Account opening procedures

Coinnor.com works with membership base. Every customer must create a username, a password and enter a valid email address for notifications. Every customer must confirm Coinnor.com Terms of use and then receives confirmation e-mail with a link. Coinnor.com opens member account only after the customer confirms the verification link sent to declared e-mail address.

 

2. Verification procedures

One of the international standards for preventing illegal activity is CDD (Customer Due Diligence). According to CDD, coinnor.com establishes its own verification procedures within the standards of AML and KYC frameworks. These include confirming the identity of our sellers and buyers by means of:

A. For Physical Persons

i.   Verifying full name of the customer

ii.  Verifying the address of the customer

iii. Verifying the  age of the customer

B. For Institutions

i.   Verifying rhe corporate documentation and business registration information

ii.  Verifying full name of the beneficial owner/owners who has more than 25% of the shares

iii. Verifying the address of the beneficial owner/owners who has more than 25% of the shares

Please read the Compliance Documents for the details of the documents and the document requirements.

 

3. Compliance officer

The Compliance Officer is the person, duly authorized by Coinnor.com, whose duty is to ensure the effective implementation and enforcement of the AML/KYC/CTF Policy. The Compliance Officer is entitled to interact with law enforcements, in prevention of money laundering, terrorist financing and other illegal activity. The Compliance Officer’s responsibility is supervising all aspects of Coinnor.com’s anti-money laundering and counter-terrorist financing, including but not limited to:

A. Collecting customers’ identification information

B. 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

C. Monitoring transactions and investigating any significant deviations from normal activity

D. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs

E. Updating risk assessment regularly

F. Providing law enforcement with information as required under the applicable laws and regulations

 

4. Monitoring transactions

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

i.   Daily check of Customers against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Customers on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable

ii.  Case and document management

B. Regarding the AML/KYC/CTF Policy, Coinnor.com will monitor all transactions and it reserves the right to:

i.   Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer

ii.  Request the Customer to provide any additional information and documents in case of suspicious transactions

iii. Suspend or terminate Customer’s Account when Coinnor.com has reasonably suspicion that such Customer engaged in illegal activity

The above list is not exhaustive, and the Compliance Officer will monitor Customers’ 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

Coinnor.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, Coinnor.com can 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.

 

6. Sanctions Policy

We are prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. We will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

 

7. Contact Us

If you have any questions, comments, or concerns regarding our AML/KYC/CTF Policy and/or practices as it or they relate to the Platform, please contact us at the E-Mail: support@coinnor.com