AML / KYC

Anti Money Laundering AML / KYC Policy

Both international and local regulations and laws require that Dollarpesa Ltd exchange service implement effective internal procedures to prevent any illegal activity and take all necessary measures to do so. The service adheres to anti-money laundering and anti-terrorist financing (AML — Anti Money Laundering) practices as well as Know Your Customer (KYC) policies.

AML / KYC policies cover the following issues:

— Verification procedures;

— Transaction monitoring;

— Risk assessment.

1. Verification Procedures.

1.1. Identity verification

The Dollarpesa verification procedure requires the User to provide the service administration with authentic documents (e.g. international passport, account statement, utility bill, etc.). For such purposes, Dollarpesa reserves the right to collect user identification information as part of its anti-money laundering policy and “Know Your Customer” policy.

Also, Dollarpesa reserves the right to further verify certain Users who have aroused suspicion. The verification process includes, providing documents confirming the User’s identity.

For individuals:

1) The User must provide one of the following documents to verify their identity:

— civil passport;

— International passport;

— ID card.

2) To confirm the address, the User must provide one of the following documents:

— A bank statement that clearly shows the address of your actual residence;

— A utility bill, which clearly shows the address of your actual residence;

— Tax documents that clearly show the address of your actual residence;

— A document proving the address of your actual residence, issued by the local authorities, which clearly shows the address of your actual residence.

For corporate clients:

1) Users must provide one of the following documents to verify their identity:

— Director’s civil passport;

— Director’s international passport;

— Director’s ID;

2) To confirm the address, the User must provide one of the following documents:

— A bank statement that clearly shows the address of your actual residence;

— A utility bill that clearly shows the address of your actual residence;

— Tax documents that clearly show the address of your actual residence;

— A document proving the address of your actual residence, issued by the local authorities, where the address of your actual residence is clearly visible.

3) To verify that the User is an authorized representative of an organization, the User must provide all of the following documents:

— A document confirming the legal address of the company;

— document confirming the registration of the legal entity;

— an order appointing the director;

— Scanned copy or photo of the letter of decision to work with Dollarpesa.

4) Information about the ultimate beneficiary:

— The civil passport of the ultimate beneficiary;

— Final beneficiary’s international passport;

— Final beneficiary’s ID;

— document confirming the final beneficiary’s address. The ultimate beneficiary, under Cypriot law, means the natural person who owns or controls the User’s Account and/or the natural person on whose behalf the transactions are carried out.

1.2 Bank Card Verification

Users who want to make an exchange involving a bank card, must first verify it. Detailed instructions on verification can be found here.

2. Monitoring transactions

Users are verified not only by verifying their identity, but also by analyzing their transactions. Therefore, Dollarpesa relies on data analysis as a tool to assess risk and detect suspicious User activity.

Dollarpesa performs data collection, filtering, record keeping, investigation management and reporting. With respect to AML / KYC policies, Dollarpesa may monitor all transactions and reserves the right to:

— Request any additional information and documents from the User in case of suspicious transactions;

— suspend or block a User’s account if Dollarpesa has reasonable suspicion that such User is engaging in illegal activity.

The above list is not exhaustive, and transactions will be monitored on a daily basis to see if transactions should be treated as suspicious.

3. risk assessment

Dollarpesa, in accordance with international requirements, checks transactions for risk using AML services.

In this regard, a transaction may be rejected if the total risk exceeds 50%.Also, the Service may refuse to provide services to the User if the risk exceeds 1.5% in the following categories:

— Dark Service — coins related to child abuse, terrorism financing, or drug trafficking;

— Dark Market — coins used for purchases;

— Scam — Coins that have been obtained by defrauding their customers;

— Mixer — Coins have been run through a mixer to make them difficult or impossible to trace. Often used for money laundering;

— Illegal Service — Coins related to illegal activities;

— Ransom — Coins obtained through extortion or blackmail;

— Exchange Fraudulent — Coins from exchanges that have been linked to fraudulent, illegal activity or have been seized by the government;

— Stolen — Stolen coins;

— Gambling — Coins related to unlicensed online casinos.

If the transaction turned out to be high-risk, the User must go through KYC verification to confirm the identity.

4. Carrying out the exchange

Dollarpesa service warns users against the attempts to use Dollarpesa for money-laundering, terrorism financing, fraud of any kind, as well as against using the service for buying prohibited goods and services.

To prevent any illegal transactions, the Service sets certain requirements for all the Requests created by the User:

4.1. The sender and the beneficiary of the Payment Request must be the same person. It is strictly prohibited to transfer funds to third parties using the Service.

4.2. The contact details stated in the User’s Order as well as other personal data must be truthful and up-to-date. The User’s personal data may be deleted from the Service database within 3 years from the date of the last Order submitted by the User.

4.3. In case the administration of the Service suspects that the User is trying to use the services of the Service for money laundering or any other illegal operations, the administration has the right to:

— Suspend the User’s exchange operation;

— Request identification documents from the User;

— Request other information related to the payments;

4.4. All of the information provided by the Client may be transmitted to controlling authorities in the following cases:

— at the request of law enforcement authorities;

— at the decision of courts of different instances;

— at the request of Administrations of Payment systems.

Personal data includes:

— surname, first name, patronymic;

— E-mail address;

— country of residence/citizenship; — details of wallets used;

— cell phone number;

— details of the identity document;

— address of the place of residence

4.5. Processing of personal data means recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), including cross-border, depersonalization, blocking, deletion, destruction of personal data, which do not fall under special categories, for the processing of which the written consent of the User is required.

4.6. The processing of personal data is made for the purpose of fulfilling the User’s obligations under the Agreement, registering the User at the Service, providing technical support, filling out Applications, providing the Services, handling requests and claims, sending informational and other kind of messages to the User’s e-mail address.

4.7. The User’s consent is the basis for the Service to process their data. This consent is given in the form of the User’s active actions, including one or all of the following: the registration of the User on the Service website and the User’s own providing the necessary data during the registration, filling the electronic form on the Service website with the aim of submitting an Order, making payment for the Order and other actions with the use of the Services.

Dollarpesa reserves the right:

1) require the User to provide additional information disclosing the origin of the digital assets and/or confirmation that the assets were not obtained by criminal means;

2) block the account and any transactions connected with the User, transfer all available information and documents concerning the incident to the financial and/or law enforcement authorities at the place of registration of the Service and, if necessary, at the Client’s registration address;

3) request from the User the documents confirming their identity, video verification, registration address, solvency;

4) return digital assets only to the account from which the transfer was made, after full verification by the Service’s security service, if it was possible to check the legal origin of the Customer’s funds;

5) Refuse to withdraw the User’s funds to third parties’ accounts without explaining the reason;

6) withhold the User’s funds until the incident is fully investigated;

7) monitor the entire chain of transactions in order to identify suspicious transactions;

8) Refuse to provide the Service to the User if the Service has reasonable suspicions about the legitimacy of the origin of digital assets or when it is impossible to trace the entire chain of movement of assets since their emergence, and to withhold funds in special accounts of the Service.