AML Policy

WALLEX Company (hereinafter referred to as the Company) implements the AML and KYC Policy (hereinafter referred to as the Policy). The goal is to prevent illegal activities in the financial sector, to promote compliance with the norms of international agreements adopted in recent years. The Policy is implemented through a procedure designed to identify the Client.

The provisions of the AML and KYC Policies are placed on the pages of this resource and are contained in other contracts with the Client. They come into force with the adoption of a General Agreement.

Terminology used in explaining the Policy.

The policy is stated using the following terms:

• The policy is considered as a set of measures aimed at preventing the legalization of income that was obtained illegally (through participation in criminal activities, the shadow economy), to prevent or at least reduce the likely risks that the Company will be involved in such activities. In the global aspect, Politics is viewed as a powerful interstate mechanism. It is intended not only to prevent the work of financial "laundries", but also to erect barriers that will not allow supporting terrorists, creating weapons capable of massively hitting the population.
• YC is a procedure that instructs financial institutions to find out what their client is. Law-abiding organizations operating exclusively within the legal framework are instructed not to conduct transactions unless the persons involved in them are identified.
• IP is a program that is used under the auspices of the US Department of Justice. The terms of the CIP require that financial companies, before offering their services, are required to identify the person interested in cooperation.
• Client – a natural or legal person who intends to receive the Company`s services, uses them, has used them before or is related to them in any way as a family member, beneficial owner (final beneficiary), employee, official from the Client`s company, etc. p.
• Prohibited behavior is illegal, in which signs of acts in the financial sphere are manifested, which the legislation recognizes as illegal.
• Fraud is a deception with selfish purposes, abuse of trust that harm others and the Company.
• Corruption is the actions of an employee, an official, manifested in illegal offers, extortion, various forms of pressure on the other side to obtain certain privileges, access to something of value.
• Money laundering – the commission of financial transactions with money, transactions with property of illegal origin, in order to conceal the identity of the owner, source or recipient of funds, to give them a legitimate appearance.
• Collusion is a secret agreement in order to achieve benefits by exerting undue influence infringing on the rights and interests of third parties, including the Company.
• Terrorist financing is support provided in one way or another that contributes to the manifestation of terrorist activity in various forms.
• Criminal behavior – this is deliberate illegal behavior that poses a threat to society.
• An Authorized Person to combat fraud (hereinafter referred to as an Authorized Person) is a person authorized to monitor and prevent cases of fraud, conduct investigations, if necessary, in order to identify Prohibited Behavior. The authorized person is directly responsible for ensuring that actions are properly carried out against persons suspected of fraud, illegal actions.

These terms are also used in third-party links on the website https://merchant.wallex.zone .

The meaning of terms not specified in the Policy is disclosed in the General Agreement.

The Policy is implemented by the Company and its representatives.

When setting out the Policy, the Company may use references to its own services and other resources, in which its intellectual property is invested.

2. LEGAL BASIS

2.1. The legal basis of the Policy is the regulations that have been adopted by the UK, FATF recommendations, including:

2.1.1. The Law of the United Kingdom "On the prevention of the legalization of funds obtained by criminal means and the financing of Terrorism". The Law was drawn up on the basis of Directives 2005/60/EC and 2006/70/EC, which were adopted by the European Union. The requirements contained in the directives have been edited and adapted to achieve compliance with national legislation, supplemented with norms that take into account the peculiarities of national legal regulation. The law regulates how to prevent attempts to legalize funds that were acquired in circumvention of the current legislation, to finance terrorist activities. It is determined who belongs to the subjects of the law, what duties, rights, responsibilities the subjects are endowed with and enjoy.

2.1.2. "Regulatory Rules for in-depth study of Clients", approved by the UK Financial and Capital Market Commission in 2008 for No. 125. They were adopted for the purpose of applying the above-mentioned law. The Rules define cases when financial institutions are supposed to take measures to obtain additional information about their customers. It has been established in what order and in compliance with what minimum volume of requirements such procedures are supposed to be carried out. The risk categories that arise when funds obtained by illegal means are legalized and terrorism is financially supported are highlighted. The signs of risk for each of the categories are indicated, special measures through the application of which it becomes possible to gain a deeper understanding of customers, the procedure according to which enhanced supervision is supposed to be carried out, which also affects customer transactions.

2.1.3. Directive (EU) 2015/849. It was adopted in 2015 by the European Parliament and the Council of Europe in order to prevent European financial institutions and the financial system as a whole from being used by structures and persons who launder money and finance terrorists.

2.1.4. The 1999 International Convention for the Suppression of the Financing of Terrorism.

2.1.5. 40 FATF recommendations.

2.1.6. Other international acts, agreements that establish regulatory measures aimed at preventing money laundering and financial support for terrorists.

2.2. The Client who has accepted the Policy, follows it, is recognized as having consented to comply with the above regulations.

3. KYC PROCEDURE

3.1. This procedure was developed to apply practically what FATF recommends: a person who intends to conduct a financial transaction is required to confirm his own identity.

3.2. KYC assumes to establish and verify the identity of the Client. The information received about the Client allows the Company to make sure that the person who contacted it for the purpose of receiving services actually lives at the specified address, is not under trial due to the commission of a crime, is not involved in any way in activities that suspect the legality of the origin of the funds that it intends to dispose of.

3.3. In order to identify the Client, it is possible to carry out the CIP procedure. It provides that the following data will be checked:

3.3.1. According to the Client`s company:

• registration number (registration was carried out through the register in which it is customary to enter legal entities in the country);
• name;
• legal address and the actual address at which the registration is actually carried out activity;
• list of authorized representatives;
• structure;
• information related to counterparties, planned transactions, contracts;
• information about owners, ultimate beneficiaries (UBO). To assess the risks of money laundering by the Client, the Company checks how they pass the KYC/AML procedures.

3.3.2. For individuals - employees of the Client`s company:

• surname, first name, patronymic;
• date, place of birth;
• residential address;
• taxpayer identification number (TIN).

3.4. The Client provides the Company with the following list of documents designed to confirm the accuracy of information about himself:

• passport (internal, foreign);
• confirmation of residence address, registration;
• phone bills;
• bank statements;
• copies of receipts for payment of utilities, etc.

This will allow the Client to successfully complete the identification procedure.

3.5. The Company has the right to request additional documents if it considers that it is necessary to identify the Client.

4. CUSTOMER IDENTIFICATION

4.1. The Company has the right to request identifying information if there are suspicions that there are signs of Prohibited Behavior in the Client`s activities. This is done to prevent money laundering, support terrorists financially, and prevent other illegal actions.

4.2. The Company checks Clients who are reasonably suspected of being engaged in activities not permitted by law.

4.3. The Company may request additional confirmations for identification if there are suspicions that the Client`s activities are illegal.

4.4. The Company has the right, without sending a warning in advance, to block the account if the activities of a person related to it have come under suspicion. In this case, the account holder is required to verify according to the KYC procedure.

5. USE, PROCESSING OF PERSONALIZED INFORMATION

5.1. The Company uses the personal data of Clients in strict accordance with the Policies adopted by it.

6. TRACKING OPERATIONS

7. CHANGES AND EDITS

7.1. The provisions of the Policy are amended and supplemented by the decision of the Company. Tracking of the relevant notifications and checking of the edits made are carried out by the Clients themselves.

7.2. If the Client refuses to accept the Policy, since it has been changed, he loses the right to receive the Company`s services. When the Client continues to use the Company`s services and products, it is recognized that he has automatically agreed to comply with the Policy with the changes made to it.

8. COUNTERING FRAUD

8.1. The Company`s General Agreement considers countering fraud as an integral part of its Policies. The Company strives to prevent fraud and other illegal actions, illegal acts that hinder its activities, harm the sphere of financial circulation, the economy, and political stability in general.

8.2. The Company carries out its activities strictly observing business, ethical, and legal standards. This gives the Company`s Clients and partners the right to expect that it will protect their interests without exposing them to the dangers arising from illegal actions, no matter from whom they come.

8.3. The policy fully complies with the norms of international law, the legislation of the United Kingdom.

9. FRAUD INVESTIGATION

9.1. The Company, having information about a person who is suspected of being directly or indirectly involved in terrorism, its financing, money laundering, fraud, has the right to conduct an independent investigation. The investigation procedure allows the use of methods and methods that provide for the norms of legislation, the General Agreement, including its integral parts (annexes).

9.2. The Authorized person is charged with the duties to detect and investigate cases of activity with signs of illegality. It takes the necessary measures to protect the interests of the Company, Customers, partners, and prevent illegal activities.

9.3. During the investigation, the Company has the right to involve third-party organizations in order to collect evidence, evidence of illegal activities and transfer them to the competent authorities.

9.4. The responsibility of the Authorized Person extends to the following:

9.4.1. Collect, store information related to suspects, including data related to the Client, transactions, transactions.

9.4.2. Report on the progress, results of the investigation, suspicions to the Company`s management, competent authorities, third parties, if necessary, provide them with information on the investigation.

9.4.3. Open, conduct, close investigations, report on any investigation in a case related to Prohibited Behavior, within its own competence. To do this, it is not necessary to warn the suspect beforehand, obtain his consent, or accept interference from the suspect person or organization. Investigations are conducted with strict objectivity and confidentiality.

9.5. The Company has the right to block the Client`s account, not to grant him access to all funds until all the circumstances of the investigation are clarified. Such measures are taken to ensure proper efficiency and to carry out the investigation procedure to the extent necessary.

Adhering to the General Agreement, the Client agrees to cooperate with an Authorized Person. This implies the obligation to promptly, in due volume, provide the requested information and documents.

9.6. The Company undertakes to maintain strict confidentiality with respect to documentation, materials related to the investigation process of Prohibited Activities. The secrecy regime is maintained so that the interests of the persons being investigated, third parties, and the investigation process itself are not harmed.

9.7. The authorized person is obliged to provide confidential information to the competent authorities, persons, organizations, if they independently conduct an investigation or provide assistance to other structures with the necessary competence.

10. LIABILITY OF THE PARTIES

10.1. The Authorized Person is responsible for tracking, investigating and preventing actions with signs of Prohibited Behavior.

10.2. The Company has the right to identify the identity of the Client, transactions in order to prove that Prohibited behavior took place, actions with signs of illegality were committed. This corresponds to the KYC policy.

10.3. The Company`s responsibility extends to the following:

10.3.1. Take appropriate measures against persons who have committed a crime, are suspected of committing.

10.3.2. Ensure proper effectiveness of control to prevent illegal actions.

10.3.3. Conduct operational investigations if Prohibited behavior, illegal actions are detected.

10.3.4. Report suspicious activity, persons carrying out it to state bodies, competent organizations.

10.3.5. Ensure that the Authorized Person reports on identified suspicious cases related to illegal acts.

11. CLIENT`S STATEMENT

11.1. The client of the Company`s service is guaranteed to refuse actions that qualify as Prohibited Behavior. The User agrees to conduct inspections in connection with the investigation, which is carried out in accordance with the Policy. The User undertakes to cooperate promptly and to the extent required with an Authorized Person who conducts investigations.

12. CHANGES AND ADDITIONS

12.1. By accepting the terms of the Policy, which may be amended or supplemented by the decision of the Company, the Client assumes the responsibility to monitor the relevant notifications provided by it, to check the relevance of the terms of cooperation (See clause 7.1).

12.2. Refusal to accept changes in the Policy implies that the Client no longer intends to request the Company`s services. Upon further use of the Company`s services, it is recognized that the Client has automatically agreed to comply with the Policy as amended (See p. 7.2).

If you have information about suspicious persons and activities related to the Company`s AML and KYC Policies, please inform our support service: ceo@wallex.zone