with “qualified” status only. In order to open an account for an individual customer, the following
information needs to be verified:
Email address;
Mobile phone number;
Full name;
Date of birth;
Proof of identity (government identity card, driver’s license, passport);
Citizenship;
Proof of residential address (utility bills, bank statement, official government letter); and
Additional information or documentation if requested.
Based on the information collected during the KYC process the Company have a right, at its own
discretion, to restricts or refuse service to a particular client.
Monitoring of Transactions
The Company uses customer transaction monitoring as a risk‐assessment and suspicious activity
detection tool. If a transaction is inconsistent with a customer’s known personal activities or personal
habits, this transaction may be considered suspicious. Data and transaction monitoring tools are used to
identify uncommon patterns of customer’s activity. After review and investigation, it is Compliance
Officer’s decision whether to file a SAR or not.
Once a SAR is filed with a relevant agency, a copy of filing documentation is maintained onsite. SAR filing
is confidential and only the Company’s employees involved in the investigation and reporting process
will be aware of its existence.
All records are retained for eight (8) years and are available upon official request by an authorized
examiner, regulator, or law enforcement agency.
Customer Due Diligence
The Company use risk based approach to select a sample of its clients for an additional verification.
We use proprietary risk assignment algorithms to reflect many aspects of customer characteristics and
behavior, including but not limited to:
account balances;
value and pattern of transactions;
consistency of data provided during customer verification process;
unusual behavior
history of devices and IP addresses used to enter the site;
origin and destination of external transfers
etc.
Sample of clients identified as high risk ones and a strata of stochastically selected clients are regulary
submitted for extended due diligence. Such due diligence involves:
verification of identity documents’ validity with issuing authorities