Anti-Money Laundering Policy and Know Your Customer Policy (hereinafter referred to as AML / KYC Policy) are aimed at preventing and mitigating the risks of the exchange bureau’s involvement in any illegal activities.
In accordance with international and local regulations, the Exchange implements effective internal procedures and mechanisms to prevent money laundering, financing of terrorism, drug and human trafficking, proliferation of weapons, including weapons of mass destruction, corruption and bribery, as well as to respond in case of any form of suspicious activity by its Users.
The AML/KYC policy includes a verification procedure, having a company official responsible for compliance with AML standards, monitoring of transactions and risk assessment. One of the international standards for preventing illegal activities is Customer Due Diligence (CDD). For this purpose, the Exchange (hereinafter – the Company) implements its own verification procedures according to strict AML standards and the «Know Your Customer» procedure;
The Company’s identification procedure requires the User to provide the Company with readable copies of documents, data or information used to identify him/her (e.g. national ID card, international passport or domestic passport, bank statement, utility bill). The Company reserves the right to collect by lawful means information on the User for the purposes of compliance with the AML/KYC Policy, and also reserves the right to demand not only copies of necessary documents, but also to demand to make them in a certain way (e.g. to take a photo of yourself together with your identity document, to record a video in a certain way, etc.).
The Company takes the necessary steps to verify the authenticity of the documents and information provided by Users. All legal methods for double checking identification information will be utilized and the Company has the right to investigate the cases of certain Users whose identities have been determined to be dangerous or suspicious. The Company has the right to verify the identity of a User on an ongoing basis, especially when the information previously provided by the User has been changed or the User’s activities appear suspicious (unusual for a particular User).
In addition, the Company reserves the right to ask Users for up-to-date documents even if they have been authenticated in the past. Once the User’s identity has been verified, the Company is not legally responsible for the User’s actions in a situation where the Company’s services are used by the User to carry out their illegal activities. AML Compliance Officer is a person duly authorized by the Exchange whose duties inсlude ensuring effective implementation and compliance with AML/KYC policies.
It is the responsibility of such officer to oversee all aspects of the company’s AML activities, including money laundering and terrorist financing. To accomplish this, the officer shall utilize the following methods, including, but not limited to, collecting user identification information, developing and updating internal policies and procedures for making, reviewing, submitting and maintaining all reports and records required by applicable laws and regulations, monitoring transactions and investigating any material deviations from normal operations. Implementing a records management systеm for proper storage and retrieval of documents, files, forms and logs. Regular updating of risk assessments.
Providing law enforcement authorities with information required by applicable laws and regulations.
The AML Compliance Officer shall have the right to cooperate with law enforcement authorities engaged in prevention of money laundering, terrorism financing and other illegal activities, including disclosing to them, if necessary, data on the client and his/her transactions through the Exchange. Users are verified not only by verifying their identity, but also by assessing their transaction behavior. Therefore, 16tonn relies on data analytics as a tool to assess risks and identify suspicious transactions. The company performs many compliance-related tasks, including data collection, filtering, record keeping, investigation management, and reporting.
systеm functions inсlude: Daily screening of users for «blacklisting» (e.g. OFAC), aggregating transmissions across multiple data points, placing users on watch and denial of service lists, opening cases for investigation when necessary, sending internal communications and completing mandatory reports when necessary; case and document management.
Providing law enforcement authorities with information required by applicable laws and regulations.
The AML Compliance Officer shall have the right to cooperate with law enforcement authorities engaged in prevention of money laundering, terrorism financing and other illegal activities, including disclosing to them, if necessary, data on the client and his/her transactions through the Exchange. Users are verified not only by verifying their identity, but also by assessing their transaction behavior. Therefore, 16tonn relies on data analytics as a tool to assess risks and identify suspicious transactions. The company performs many compliance-related tasks, including data collection, filtering, record keeping, investigation management, and reporting.
systеm functions inсlude: Daily screening of users for «blacklisting» (e.g. OFAC), aggregating transmissions across multiple data points, placing users on watch and denial of service lists, opening cases for investigation when necessary, sending internal communications and completing mandatory reports when necessary.
The Company reserves the right to monitor all transactions and ensure that suspicious transactions are reported to the appropriate law enforcement authorities through the AML Compliance Officer, to request any additional information and documents from the User in case they carry out suspicious transactions, to suspend transactions, suspend or terminate the User’s account if there is reason to believe that such User is involved in an illegal transaction, and to suspend or terminate the User’s account if there is reason to believe that such User is involved in an illegal transaction.
The above list is not exhaustive and the AML compliance officer,on a daily basis, may perform other checks not contrary to law and decide whether such Users or transactions should be reported and treated as suspicious or may be treated as bona fide.
By applying risk assessment practices to combat money laundering, the Company ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified. The Company reserves the right to suspend any exchange transaction and require the client to verify his/her identity in accordance with the above rules, as well as documents confirming the origin of funds (and/or cryptocurrency) sent by the client under the exchange application.
If the Client refuses to undergo identity verification and/or refuses to provide documents confirming the origin of funds or cryptocurrency on the exchange application, the Company will suspend the transaction and conduct an additional investigation until receiving information from law enforcement and regulatory authorities. If the Client provides all necessary documents, the Company undertakes to make a refund or complete the exchange within 7 (seven) calendar days
