KNOW YOUR CUSTOMER

Know Your Customer (KYC) Protocols

 

Financial institutions and banks around the world have been increasingly implementing Know Your Customer (KYC) policies, which are designed to protect users from all types of fraudulent activities, such as identity theft, financial fraud and money laundering. These policies even target preventing terrorist activities.

 

Criptouch’s policy is zero tolerance when it comes to fraudulent activities. This means we have taken all possible measures available to prevent fraud. We will carefully document all fraudulent activities and all accounts related to such activity will be closed immediately.

Prevention

 

Criptouch has a proactive strategy when it comes to combating fraudulent activity and protecting the personal data of our users. Our comprehensive security protocols ensures the safety of any personal data you provide to us. At Criptouch, your safety and security are of utmost importance and we will do all that is necessary to ensure you are not a victim of any type of fraudulent activity. In order to secure your electronic transactions, you will be required to provide us with certain data, including your preferred deposit method.

Defining ‘Customer’

 

For purposes of our KYC protocols, a ‘Customer” is defined as follows:

 

·         An individual who has an account and/or maintains a business relationship with the specified Company;

 

·         An individual with an Account registered with the Company and has conducted financial activities or a financial transaction with the Company;

 

·         An individual who is the beneficial owner of the Account that is registered and maintained;

 

·         Any other individual or party connected with a financial transaction posing possible risk to the reputation or other risks to the Company.

 

The guidelines regarding Customer relationship with the Company are as follows:

 

Accounts are not to be opened anonymously or using a fictitious name;

 

Acceptance of new Customers only after the verification of identity. The client must also declare he or she is at least 18 years of age. Also, we will check to ensure the Customer identity does not match any individual with a criminal history or has no connections with prohibited entities;

 

Classify Customers using various risk categories, based upon perception of risk, while applying criteria for acceptance for each risk category of Customers. If considered necessary, Customers requiring extraordinarily high levels of monitoring, e.g. Politically Exposed Individuals, may be put into a High Risk Category.

 

Requirements for documentation and other specified information will be collected in accordance with different Customer categories based upon perceived risk as well as compliance with Anti-Money Laundering laws.

 

No accounts will be opened or closed in the case that the identity of the holder of the account cannot be verified and/or information/documentation required cannot be confirmed in accordance with the applicable risk category, due to the Customer’s non-cooperation or the unreliability of the submitted information.

 

Decisions of whether or not to open a new account for a Politically Exposed Person (PEP) will be made at a senior management level. In some cases, it will be deemed necessary to implement safeguards of harassment of said customer. For instance, decisions to close an individual’s account may be made after the customer has been given due notice with explanation of reasons for making such a decision.

 

No Customer shall be permitted, under any circumstances, to act on the behalf of another individual.

 

Anti-Money Laundering (AML) and Know Your Customer (KYC) protocols aim to ensure, prior to acceptance of Customer funds, all practical and reasonable measures have been taken to confirm the identity of Customer. The Company will also verify that any third party, which the Company relies upon for identification of a Customer, such as a banking firm or financial services firm, also complies with the same standards as the Company.

 

These procedures for Customer Identification are premised on the assumption that the Company will be accepting funds from new and existing Customers only after the following:

 

Customer identity has been confirmed by the Company and that the Company has verified that the Customer is not acting on behalf of or for the benefit of any third party without specific disclosure of such intent that has been submitted to the Company by the Customer;

 

or:

 

If Customer is acting for the benefit of or on behalf of a third party, and the Company has verified identities of all underlying third parties.

 

Identification Of Natural Person

The Company will take steps deemed reasonable for ascertaining evidence, which is satisfactory for verifying the Customer’s name, location of birth, date of birth, address of employer and source of Customer’s deposited funds. For purposes of confirming the Customer’s identity, the Company will require the submission of copies of the following specified documents to be retained in the records of the Company:

 

·         Passport or other government-issued identifying document;

·         Power of attorney documentation (if applicable, along with contact information of entity granted power of attorney).

·         Declaration of Application Form with Due Diligence, including:

1.       Applicant’s identifying details

2.       Address of Applicant

3.      Annual income, income source, occupation and shareholder categorization

4.      Banking information

5.      Custody, settlement and clearing agent

6.      Photograph of Customer with handwritten note along with identifying documentation

7. Documentation which may be required include:

 

-          Bank statements or utility bills; or other document identifying Customer’s residence;

-          Banking references

 

The Company’s Compliance Officer will always have the right to request from any Customer additional documents in order to adhere to KYC/AML standards and to investigate any potential suspicious activity, such as money laundering or identity theft. The Company is entitled to discontinue cooperation with the Customer or not enter into a relationship with the Customer if the Customer fails to refute any suspicion. The Company has the right to report any illicit activities to the appropriate authorities.

Entity Identification

The Company will take actions that are reasonable to confirm satisfactory evidence proving the accuracy of an entity Customer’s name and address and the entity’s authority to make investments. The Company will obtain the following documentation:

 

●        Declaration over Application Form with Basic Due Diligence that includes:

 

1. Name of entity
2. Description of economic activity of entity
3. Address of entity
4. Applicable registration number
5. List of executives, directors and shareholders
6. Information of ultimate beneficiary information
7. Tax ID number
8. Relevant license information
9. Supporting documentation which includes:

● Copy of resolution which grants the Principals/Directors authority to act;

● Articles of Association and Articles of Memorandum;

● Certificate of Incorporation;

● List of Directors/Principals;

● Comprehensive list of authorized signatories

● Description of primary business;

● Information which is publicly available from regulatory agencies or law enforcement authorities;

● Annual report, if applicable, or bank references;

● License (if applicable);

● Passport or other government-issued document, bank statement, bank reference, utility bill and curriculum vitae of ultimate beneficiary owner.

 

The Company’s Compliance Officer will always have the right to request from any Customer additional documents in order to adhere to KYC/AML standards and to investigate any potential suspicious activity such as money laundering or identity theft. The Company is entitled to discontinue cooperation with Customer or to not enter into relationship with Customer if the Customer fails to refute any suspicion. The Company has the right to report any illicit activities to appropriate authorities.

Definition of High-Risk Customers

 

The Company’s Compliance Officer will keep updated a list of the types of Customers that the Company categorizes as “high risk,” such that enhanced procedures for due diligence are warranted in comparison to routine procedures for identifying Customers.

 

The following lists examples of Customers who would be categorized as high-risk:

 

● A High-Level Foreign Political Official or Figure or any immediate family member of a High-Level Foreign Political Official or Figure (Politically Exposed Persons or PEPs defined by FATF recommendations are also included in this category);

• A High-Level Domestic Political Figure, any member of a High-Level Domestic Political Figure’s Immediate Family, and any Close Associate of a Senior Domestic Political Figure (Politically Exposed Persons or PEPs defined by FATF recommendations are also included in this category)
• Any Client resident in, or organized or chartered under the laws of, a Non-Cooperative Jurisdiction;

Note: Non-Cooperative Jurisdiction refers to any foreign country that has been designated as non-cooperative with international anti-money laundering (AML) principles or procedures by an intergovernmental group or organization, such as the Financial Action Task Force on Money Laundering (“FATF”).

 

• Any Client who gives the Compliance Officer any reason to believe that its funds originate from, or are routed through, an account maintained at an “offshore bank”, or a bank organized or chartered under the laws of a Non-Cooperative Jurisdiction; and
• Any Client who gives the Compliance Officer any reason to believe that the source of its funds may not be legitimate or may aid terrorist activities.

 

Non-cooperative Jurisdiction may be reason for rejecting cooperation with a Customer associated with the following non-cooperative jurisdictions, which include:

 

United States

New York (NY)

Georgia (GA)

Connecticut (CT)

New Mexico (NM)

Washington (WA)

Hawaii (HI)

Afghanistan

Bosnia and Herzegovina

Cuba

Ethiopia

Iran

Iraq

Democratic People’s Republic of Korea

Lao People's Democratic Republic

Sri Lanka

Sudan

Syrian Arab Republic

Trinidad and Tobago

Tunisia

Uganda

Vanuatu

Yemen

Lebanon

Serbia

Algeria

Bangladesh

Bolivia

Cambodia

China

Kyrgyzstan

Macedonia

Nepal

Nigeria

Thailand

 

High-Risk Customer Identification

The Company shall take action that is reasonable to confirm the evidence of a High-Risk Customer’s full name and address of residence. The Company will ascertain the following, in accordance with what is appropriate for the circumstances. High-Risk Customers are subject to enhanced due diligence procedures, including stricter requirements to reach compliance.

 

In addition to all required documentation for verifying the identification of a natural person or entity via basic due diligence requirements, enhanced due diligence requirements will include but are not limited to the following:

 

●Assessment of Customer’s business reputation and history via reviewing financial and professional references, publicly available media reports or via other means;

●Examining the source of Customer’s wealth, including economic activity generating income and wealth and source of specific funds which are intended to be utilized for investment purposes;

●Reviewing publicly available information such as reports in the media, to determine if Customer has been subject to civil or criminal enforcement actions based on violating anti-money laundering laws or

●if Customer has been subject to investigation, conviction, indictment or civil enforcement related to the financing of terrorism;

●Requiring an in-person meeting with Customer to confirm and discuss the documents submitted by Customer to open the new account;

●Review of recent changes in senior management or ownership of entity;

●Requiring visit to Customer’s place of business in order to conduct an in-person meeting with Customer to confirm account application, the purpose for opening the account and the source of assets

 

The Company’s Compliance Officer will always have the right to request from any Customer additional documents to adhere to KYC/AML standards and to investigate any potentially suspicious activity, such as money laundering or identity theft. The Company is entitled to discontinue cooperation with the Customer or not enter into a relationship with Customer if the Customer fails to refute any suspicion. The Company has the right to report any illicit activities to the appropriate authorities.

 

Identification Requirements for Transactions

The Company is entitled to request documents required for compliance with AML/KYC protocols. The list of required documents may vary depending upon the sum of transactions.

Please pay attention that Client is obliged to provide all the documents requested by the Company. Client is obliged to provide all requested KYC documents within 72 hours after he made Bitcoin purchase from LordOfCoins. If Client failed/refused to provide requested documents to the Company and does not cooperate with LordOfCoins, the Client shall be imposed to pay liquidated damages in the amount of 2,500 EUR without any proof of damage. In addition, the Company will be able to file a lawsuit and initiate legal actions against Client.

 

KYC Requirements for Credit Cards:

·         Identification Document – Any amount.

·         Copy of credit card (front and back) – Can be requested from the amount of 750 euros (EUR).

·         Proof of Residential Address - Can be requested from the amount of 750 euros (EUR).

·         Declaration of Purchase - Any amount (signed online).

·         Photograph of self with ID along with handwritten note – For transactions higher than 5000 euros (EUR).

·         For transactions higher than 30,000 euros (EUR), the Company’s Compliance Officer may require phone verification and/or Source of funds.

 

KYC Requirements For Bank Transfers:

·         Identification Document – Any amount 

·         Copy of credit card (front and back) – Any amount 

·         Proof of Residential Address - Any amount

·         Declaration of Purchase - Any amount (signed online)

·         Photograph of self with ID along with a handwritten note – For transactions higher than 5000 euros (EUR).

·         For transactions higher than 30,000 euros (EUR), the Company’s Compliance Officer may require phone verification and/or Source of funds.

 

PLEASE NOTE THAT CUSTOMERS WILL RECEIVE PURCHASED BITCOIN ONLY AFTER THE FULL VERIFICATION OF YOUR ACCOUNT WITH CRIPTOUCH!

 

KYC Policy updates

The Criptouch KYC policies may be changed or updated in accordance with current laws and international regulations.

 

If you have any questions or queries, please do not hesitate to contact our customer support: support@criptouch.com.