AML/KYC Rules
For the purposes of this policy, "we", "us" or "our" refers to AimHash.
Our Anti-Money Laundering and Know Your Customer Policy (hereinafter - "AML/KYC Policy") is designed to prevent and mitigate possible risks of our being involved in any kind of illegal activities.
{0} services are not available to individuals or legal entities located in or having their habitual residence or registered office in the United States or any other country where {0} does not provide services. As long as you maintain your registered account on {0}, you represent and warrant that you are not located in the United States and are not a resident of the United States. You must also not use the Service if you are located in or a resident of a Prohibited Jurisdiction. "Prohibited Jurisdiction" means any state, country, territory or other jurisdiction that is subject at any time to comprehensive, geographic-targeted sanctions by the United Nations, United States, Central Bank of Ireland, European Union (1) lists and "High-Risk Third Countries and International Context Content on Anti-Money Laundering and Countering the Financing of Terrorism" list, OFAC, or identified by FATF as "Call for Action" jurisdictions or "Monitored Jurisdictions"; (2) where your use of the Services would be illegal or would breach any applicable laws, or (3) that {0} determines in its sole discretion is ineligible for access to and use of the Services.
Both international and local regulations require us 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 our customers.
AML/KYC Policy covers the following matters:
- Compliance Officer;
- Risk-Based Assessment;
- Verification Procedures;
- Transaction Monitoring and Sanctions Screening.
Compliance Officer
The Compliance Officer is our formally authorized person responsible for ensuring effective implementation and enforcement of the AML/KYC policy. The Compliance Officer is responsible for overseeing all aspects of our anti-money laundering and counter-terrorist financing measures, including but not limited to:
- Collecting customer identification information;
- Providing relevant KYC/CDD, including PEP status detection and ultimate beneficiary detection;
- Developing and updating internal policies and procedures for completing, reviewing, submitting and retaining all reports and records required by applicable laws and regulations;
- Monitoring transactions and investigating any significant deviations from normal activity;
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- Updating risk assessment periodically;
- Providing information to law enforcement authorities according to applicable laws and regulations;
- Providing sanctions screening;
- Providing training for relevant personnel;
The Compliance Officer has the authority to interact with law enforcement agencies involved in prevention of money laundering, terrorist financing and other illegal activities.
Risk-Based Assessment
We follow international requirements by taking a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be allocated according to priorities so that the greatest risks receive the highest attention.
Verification Process
One of the international standards for preventing illegal activity is customer due diligence ("CDD"). According to CDD, we have established our own verification procedures within the standards of anti-money laundering and "Know Your Customer" frameworks.
a) Identity Verification
Our identity verification procedure requires the customer to provide reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For this purpose, we reserve the right to collect customer's identification information for the AML/KYC Policy purposes.
We will take steps to confirm the authenticity of documents and information provided by the customers. We will use all legal methods for verifying the identity information, and we reserve the right to investigate certain customers who have been determined to be risky or suspicious.
We reserve the right to verify customer's identity on an ongoing basis, particularly when their identification information has been changed or their activity seems to be suspicious (unusual for the particular customer). In addition, we reserve the right to request up-to-date documents from the customers, even though they have passed identity verification in the past.
We will collect, store, share and protect your identity information strictly in accordance with our Privacy Policy and relevant regulations.
Once the customer's identity has been verified, we are able to remove ourselves from potential legal liability in a situation where our services are used to conduct illegal activity.
b) Card Verification
Customers using payment cards in connection with our services may be required to complete card verification. This may include:
- A scan/photo of the card statement showing payment for our services.
- A scan/photo of the payment card (both sides). We require the cardholder's name and signature, and the first 6 and last 4 digits of the card number to be clearly visible. The CVV code and remaining digits must be hidden with paper.
- A selfie of the customer holding the payment card (with only the first 6 and last 4 digits clearly visible) and a paper with "@(ViewData["WebSiteName"])" and current date written on it at the moment of taking the selfie.
- Any other documentation proving the payment was indeed authorized by the cardholder.
c) Source of Wealth/Funds and Origin
According to our policy, we require customers to explain and sometimes prove your source of funds and/or source of wealth that you work with us. This must be done not in a formal way but to let us reasonably understand that the funds you use are not connected with illegal activities, are not sanctioned and are indeed yours.
d) PEP Status Detection
You have the responsibility to inform us whether you or your relatives are or have been PEPs, but we reserve the right to obtain information from different sources for verification, and if so, we reserve the right to provide you with a high-risk approach.
Transaction Monitoring and Sanctions Screening
Knowing your customer is not only about verifying their identity (who they are), but more importantly about analyzing their transaction patterns (what they do). Therefore, we rely on data analysis as a risk assessment and suspicious detection tool. We perform various compliance-related tasks including data capture, filtering, record-keeping, investigation management, and reporting. System features include:
a) Daily checking of customers against recognized "blacklists" (e.g., OFAC, EU sanctions lists, etc.), aggregating multiple data points of transfers, placing customers on watch and service denial lists, opening cases for investigation when necessary, sending internal communications and completing statutory reports (if applicable).
b) Case and document management.
Regarding the AML/KYC policy, we will monitor all transactions and reserve the following rights:
- Ensure suspicious transactions are reported to appropriate law enforcement through the compliance officer;
- Request additional information and documents from customers in case of suspicious transactions;
- Suspend or terminate customer accounts when we have reasonable grounds to suspect illegal activities.
c) Travel Rule
Following FATF recommendations, we have established rules for obtaining, holding and transmitting originator and beneficiary information for any virtual asset transactions to identify and report suspicious transactions, monitor the availability of information, take freezing actions and prohibit transactions with designated persons and entities. We apply all monitoring and anti-money laundering measures to destination wallets even if the beneficiary is not a company customer.
We always obtain and hold (if we have such data) originator information and beneficiary information of transactions and their destination wallet information.
The above list is not exhaustive, and the Compliance Officer will monitor customers' transactions daily to determine whether such transactions should be reported and treated as suspicious transactions or should be treated as bona fide transactions.