introduction
15863201 Canada Anti-Money Laundering and Know Your Customer Policy (hereafter "the AML / KYC policy") is designed to prevent and mitigate the possible risks of 15863201 Canada being involved in any kind of illegal activity.
Both international and international regulations require 15863201 Canada to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drugs and human trafficking, the proliferation of weapons of destruction mass, corruption and corruption and to act in the event of any form of suspicious activity by its users.
The AML / KYC policy covers the following aspects:
1. Verification Procedures
One of the international standards for the prevention of illegal activity is the Customer Due Diligence ("CDD"). According to CDD, 15863201 Canada establishes its own verification procedures under the anti-money laundering and "Know Your Customer" standards.
1.1. Identity verification
The 15863201 Canada identity verification procedure requires the User to provide 15863201 Canada with independent and reliable documents, data or information of origin (eg national ID, international passport, account statement, bill). To this end, 15863201 Canada reserves the right to collect user identification information for the purposes of the AML / KYC policy.
15863201 Canada will confirm the authenticity of the documents and information provided by users. All legal methods for the double checking of identification information will be used and 15863201 Canada reserves the right to investigate certain Users who have been determined to be risky or suspicious.
15863201 Canada reserves the right to verify the identity of the User on an ongoing basis, in particular when his identification information has been changed or their activity has seemed suspicious (unusual for the particular User). In addition, 15863201 Canada reserves the right to request updated documents from Users, even if they have passed identity verification in the past.
User identification information will be collected, stored, shared and strictly protected in accordance with the 15863201 Canada 's privacy policy and related regulations.
Once the identity of the user has been verified, 15863201 Canada is able to remove itself from a potential legal liability in a situation where its Services are used to carry out illegal activities.
1.2. Card verification
Users who intend to use payment cards in connection with the 15863201 Canada Services must pass the card verification in accordance with the instructions available on the 15863201 Canada website.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by15863201 Canada , who is responsible for ensuring the effective implementation and application of the AML / KYC policy. It is the responsibility of the Compliance Officer to oversee all aspects of15863201 Canada 's anti-money laundering and anti-terrorism funding, including but not limited to:
a. Collection of user identification information. b. Establish and update internal policies and procedures for the completion, review, presentation and preservation of all reports and records required by applicable laws and regulations. c. Monitor transactions and investigate any significant deviations from normal activity. d. Implementation of a record management system for the appropriate storage and retrieval of documents, files, forms and records. is. Periodic update of the risk assessment. f. Provide law enforcement agencies with the information required by applicable laws and regulations.
The Compliance Officer has the right to interact with law enforcement agencies, which are involved in the prevention of money laundering, terrorist financing and other illegal activities.
3. Monitor transactions
Users are known not only by verifying their identity (who they are) but, above all, by analyzing their transactional patterns (what they do). Therefore, 15863201 Canada is based on data analysis as a tool for assessing risks and detecting suspects. 15863201 Canada carries out a series of compliance-related activities, including data acquisition, filtering, record keeping, investigation management and reporting. System features include:
1) Daily control of users against recognized "black lists" (eg OFAC), aggregation of transfers from multiple data points, placement of users on the lists of supervision and assistance denialists, opening of cases for investigations where necessary , sending internal communications and filling in statutory reports, if applicable;
2) Case and document management.
Regarding the AML / KYC policy, 15863201 Canada will monitor all transactions and reserves the right to:
The list above is not exhaustive and the Compliance Officer will monitor the Users' transactions daily in order to define whether such transactions should be reported and treated as suspicious or to be treated as in good faith.
4. Risk assessment
15863201 Canada , in line with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, 15863201 Canada is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be addressed according to priorities so that the greatest risks receive the greatest attention.
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