INVCOIN24 OÜ (hereinafter – ‘INVCOIN24’) Anti-Money Laundering and Know Your Customer Policy (’AML/KYC Policy’) is designed to ensure the compliance of INVCOIN24 and its services with applicable law and make sure that neither INVCOIN24 nor any of its services or websites are used for illegal activities.
Unless otherwise specified, or required by reasonable or necessary implication, terms in this AML/KYC Policy have the same meaning as terms defined and used elsewhere in our Terms of Serice and our Procedural Rules.
Please refer to our Procedural Rules to get more information about terminology and pricniples used in this AML/KYC Policy.
INVCOIN24 AML/KYC Policy is applied to both legal and natural persons.
AML/KYC Policy covers the following points:
Compliance Officer’s Duties and Obligations;
Principles of Monitoring Transactions;
Risk Assessment principles.
INVCOIN24 applies the principles of Customer Due Diligence (’CDD’) and Know Your Customer (’KYC’) frameworks during its verification procedures.
INVCOIN24 proceeds from a risk-based approach and constantly evaluates the risk of money laundering and terrorist financing in various activities and actions, and, if necessary, applies enhanced measures of thorough verification.
INVCOIN24 has the right, at any time, to change or modify the Terms of Service applicable to your use of our Services, or any part thereof (including this AML/KYC Policy). Such changes and modifications shall be effective immediately upon notice thereof. This notice may be given by means including, but not limited to, updating the date of the version of the document, by email or by other means.
In order to use INVCOIN24 services, natural and legal persons must be identified. INVCOIN24 requires its users to provide accurate, true and up-to-date information and documents necessary for verification procedure.
We have selected a senior management team to act as a Chief Compliance Officer to make the communication between us and governing authorities clearer and more efficient. The key role of the nominated officer is to create a framework where any member of our staff has sufficient skills and knowledge to raise suspicions of money laundering or terrorist financing. Our staff members also have a clear procedure to report their suspicions in due time.
INVCOIN24 may refuse to provide services to those users, who provided false, inaccurate or outdated data, or who are suspected to conduct illegal activities such as money laundering.
INVCOIN24 OÜ establishes the identity of natural person and, if applicable, also the identity of the authorized representative of the natural person, and stores information about them. INVCOIN24 OÜ establishes the identity of an individual based on the following documents:
identity card: digital identity card or residence permit card;
the passport of the foreigner;
temporary exit document;
refugee exit document;
certificate of return;
permission to return;
ID card of a citizen of the European Union;
driver's license if the name, photo or image of the person, signature or image of the signature and date of birth or personal identification number of the customer are present on the document.
In addition to identifying the person, the address of the place of residence, the profile of the activity, the profession and the sphere of activity of the person, the purpose and nature of the establishment of the business relationship, if necessary, a real beneficiary and other similar important information for establishing a business relationship are verified. In the case of a client with a high degree of risk, INVCOIN24 asks the user to provide additional information/confirmations regarding the submitted data (request a bill for their telephone or housing expenses).
INVCOIN24 establishes the identity of the legal entity on the basis of the following documents:
registration card of the corresponding register;
registration certificate of the corresponding register;
registration certificate issued by Tax Authority;
documents proving the status and identities of owners and ultimate beneficiaries;
certificate of good standing if company is registered for more than 2 years;
copy(ies) of passport(s) of director(s) of the legal person;
a letter from bank, where the legal person owns an account, proving reliability;
or other documents equal to those stated above.
The Compliance Officer is the person appointed by INVCOIN24 and who ensures the effective implementation and enforcement of the AML/KYC Policy.
INVCOIN24 Compliance Officer’s duties include:
Collecting Users’ identification information.
Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the 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 regularly.
Providing authorized court, law enforcement and government agencies with information as required under the applicable laws, court decisions and regulations.
The Compliance Officer is entitled to interact with law enforcement agencies, which are involved in prevention of money laundering, terrorist financing and other illegal activities.
All transactions and actions of users which lack a clear economic or legal reason, and which cannot be considered to be ordinary business activities of users are treated as unusual. INVCOIN24 decides whether the transaction is unusual on the basis of a set of circumstances known about the user and the transaction, considering that the user may suffer from unreasonable suspicion.
INVCOIN24 checks official international databases of persons under international sanctions and other legal instruments.
INVCOIN24 reserves the right to suspend provision of services, temporary or permanently block any accounts or wallets, request users to provide additional information and/or documents in case of any suspicion related to money laundering or other illegal activities.
INCOIN24 uses risk-based approach to combat money laundering and other illegal activities. In order to identify, evaluate and analyze the risks associated with money laundering and terrorist financing,
INVCOIN24 takes into account the following risk categories:
risks associated with the client;
risk associated with States or geographical areas or jurisdictions;
risk associated with services and transactions;
the risk associated with mediation channels or communication between an obligated entity and customers, or channels for the transfer of goods, services or transactions.
INVCOIN24 uses ‘high’ and ‘low’ risk levels during the evaluation and provision of services.