Anti-Money Laundering and Counter-Terrorist Financing (AML) and Know Your Customer (KYC) Policy of the SpbWMCasher Service
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1. Goals and Scope of Application
1.1. This document (hereinafter referred to as the “Policy”) establishes standards and procedures aimed at identifying, preventing, and suppressing attempts to use the infrastructure of the SpbWMCasher service for money laundering, financing illegal activities, or other actions contrary to international and national legislation.
1.2. Money laundering is the concealment of the illegal origin of funds by converting them into assets or investments that appear legitimate. The SpbWMCasher service categorically warns Users against any attempts to use the Service for such purposes, as well as for financing terrorism, drug and human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery.
1.3. The SpbWMCasher Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the “AML Policy”) and the Know Your Customer Policy (hereinafter referred to as the “KYC Policy”) are designed to prevent and reduce potential risks of the Service being involved in any illegal activity.
1.4. International laws and regulators, as well as the Fifth Anti-Money Laundering Directive (5AMLD), require services providing virtual/cryptocurrency asset services to implement effective internal procedures and mechanisms to prevent illegal activities.
1.5. By creating a request on the Website, the User consents to the possibility of undergoing an AML/KYC check.
1.6. The exchange office, as a virtual asset service provider, is obliged to screen all suspicious transactions. During the screening process, it is necessary to identify the User (KYC) and establish the origin of the asset. The asset is held in the balance during the screening period.
2. General Requirements and Prohibitions
2.1. In its activities, SpbWMCasher adheres to the following principles:
— not to enter into business relationships with known criminals and/or terrorists;
— not to process transactions that result from known criminal and/or terrorist activity;
— not to facilitate any transactions related to such activity;
— not to enter into business relationships with persons directly or indirectly involved in terrorist activities, transnational crime, or corruption.
2.2. To prevent illegal transactions, the Service establishes the following requirements for all Requests: the sender and recipient of the payment for the Request must be the same person. Using the Service on behalf of third parties is prohibited.
3. AML Officer and Transaction Monitoring
3.1. To ensure compliance with this Policy, the SpbWMCasher service appoints a responsible employee — the AML Officer (Money Laundering Reporting Officer), whose responsibilities inсlude:
— creating and updating internal policies and procedures in accordance with current legislation and FATF recommendations;
— monitoring transactions and analyzing significant deviations from standard User behavior;
— regularly reassessing customer risk profiles;
— preparing and storing all reports required by applicable law.
3.2. The AML Officer is authorized to interact with law enforcement and supervisory authorities on matters related to preventing money laundering and terrorist financing.
3.3. Transaction monitoring and analysis of collected data are tools for risk assessment and detecting suspicious transactions. If there are reasonable grounds for suspicion, the SpbWMCasher Service reserves the right to:
— file a suspicious transaction report with the authorized financial intelligence unit;
— request additional explanations and documents from the User;
— suspend or terminate the User’s account;
— suspend the exchange and freeze assets pending clarification;
— return funds to the User by canceling the transaction in accordance with the User Agreement;
— deactivate the User’s account without the right to reinstatement if a violation is established.
3.4. In accordance with international requirements, the SpbWMCasher Service applies a risk-based approach. The level of scrutiny applied to a User and their transaction corresponds to the degree of potential risk, ensuring the proportionality of the measures applied.
4. AML/KYC Screening Procedure
4.1. The AML/KYC screening procedure for Users and transactions is carried out by the AML Officer of the SpbWMCasher service using specialized analytical systems (Chainalysis, Crystal, AML Bot, and others).
4.2. The AML/KYC procedure includes the following set of measures:
— conducting continuous monitoring of transactions processed through the SpbWMCasher service;
— appointing a responsible person (Money Laundering Reporting Officer / AML Officer);
— applying a risk-based approach to assessing Users and transactions;
— conducting due diligence on Users;
— regularly reassessing User and product risk profiles;
— enhancing the professional competence of Service employees;
— cooperating with state and law enforcement authorities in cases provided for by law;
— maintaining records and documentation in accordance with legal requirements.
4.3. As part of the AML/KYC screening, the User consents to the processing and storage of their personal data and, if necessary, to their transfer to authorized bodies and analytical service providers.
5. Grounds for Freezing a Transaction
5.1. The Service does not support transactions that have passed through mixers (tumblers) or other anonymizing services.
5.2. A User’s transaction may be frozen indefinitely until full identity verification (KYC) is completed in the following cases:
If, based on the results of an AML analysis of cryptocurrency assets in one of the analytical services (Chainalysis, Crystal, AML Bot, CoinKYT, GetBlock, Match Systems, Shard, WamlApp), a risk level above 60% is detected, or any of the following risk tags are assigned: DARK MARKET, DARK SERVICE, SCAM, STOLEN COINS, MIXING (MIXER), SEXTORTION, RANSOM, HACK, PHISHING, TERRORISM FINANCING, FRAUD, BLACKLIST, STILL UNDER INVESTIGATION, CYBERCRIME ORGANIZATION, NARCOTICS, CHILD ABUSE, HUMAN TRAFFICKING, SANCTIONS, ILLEGAL SERVICE, GAMBLING, as well as other high-risk tags.
5.3. A transaction may be frozen if any suspicious activity is identified by the AML Officer of the SpbWMCasher service during ongoing monitoring.
5.4. A transaction may be frozen upon receipt of a formal request from an analytical service provider or liquidity partner.
5.5. A transaction may be frozen upon receipt of an official request from competent state or law enforcement authorities.
6. Documents for Undergoing KYC Verification
6.1. To verify identity, the User must provide:
— a photo of one of the following documents: passport, ID card, or driver’s license;
— a selfie with the specified document and a handwritten note containing the date of creation and the User’s signature;
— a statement from the banking application (PDF/screenshot) or a screen recording confirming the transaction.
6.2. To confirm the origin of funds, the Service has the right to request the following documents and information from the User:
— which platform the funds were received from; screenshots of withdrawal history from the sending wallet/platform, as well as links to both transactions in a blockchain explorer;
— what service the funds were received for or as payment for;
— the transaction amount, date, and time;
— which contact person facilitated the interaction with the sender of the funds; screenshots of correspondence confirming the transfer.
6.3. All provided images (scans, photos, screenshots) must be in JPEG or PNG format and provide adequate quality for identification.
6.4. If necessary, the Service has the right to request any other documents not specified in this section.
7. Consequences of Passing/Failing the Verification
7.1. User assets that do not pass the AML check are not eligible for exchange. The return of frozen assets is possible only after successfully passing the KYC check.
7.2. The review period for documents submitted by the User for KYC verification is no more than 5 (five) business days from the date the Service receives the complete set of requested materials.
7.3. Upon successful completion of KYC verification and a positive decision by the Service, the frozen funds will be returned within 30 (thirty) calendar days from the date of verification completion. The return is made to the sender’s details, deducting only the network fee, without additional charges.
7.4. If the User refuses to undergo the KYC verification procedure or fails to provide the requested documents, the Service has the right to consider such inaction as a sign of bad faith and transfer information about the relevant transaction and associated assets to the authorized financial intelligence units, financial intelligence agencies, and/or law enforcement authorities in accordance with applicable law. The assets may be frozen until a decision is issued by the competent authority.
7.5. The return of assets is impossible if a request from competent authorities has been received regarding these assets, or if they have been seized/blocked by other agencies of any jurisdiction. In such a case, the frozen asset may be held as material evidence in legal proceedings.
8. Geographic Restrictions
8.1. To reduce the risk of involvement in illegal activities, the Service restricts or completely prohibits the provision of services to individuals who are citizens or residents of the following countries: Afghanistan, Bosnia and Herzegovina, USA, Democratic People’s Republic of Korea (DPRK), Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People’s Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine, as well as other states subject to sanctions by the UN or relevant international regulators.
8.2. The current list of restricted jurisdictions may be amended unilaterally in accordance with updates to FATF lists and international sanctions regulations.
9. Requests from State and Law Enforcement Authorities
State and law enforcement authorities have the right to send information requests through the official communication channels listed on the Website. Each interaction case is considered individually, strictly in accordance with applicable law and this User Agreement.
