AML/KYC

Digital cryptocurrency exchange service CoinBirexy, complies with all norms laws that apply in the country of residence this service. The operation of the service does not violate the laws of other countries, whose citizens can use the services of an exchanger, observing established rules.

The security of the service is given special attention. Exchange online cryptocurrency points can be used by attackers to legalization of proceeds obtained illegally or from illegal activities. There is a possibility of financing terrorism through digital money transfers.

To prevent such illegal operations when using service and secure transactions of other users, AML / KYC policy, provisions and documents governing the principles of operation of the digital service and The rules for using the exchanger have been changed.

The new provisions of the service policy are mandatory, strictly adhered to by employees to minimize the risks, related to the use of the exchanger.

The available resources that the Service has allow you to discover suspicious financial transactions with cryptocurrency and deal with them check. Disclose the details and mechanisms used in the work, aimed at combating illegal activities, we will not security.

The digital Service retains the right to require the user to pass identification or provide the documentation requested by the exchanger, to verify the legal origin of the funds. Similar information is also required for user identification (KYC).

Service CoinBirexy indicates that the identity verification process users conducting transactions are conducted using their own service resources and with the involvement of third-party organizations that are engaged in identification of an individual or check how respected AML policy user.

1. AML Policy Statements

1.a AML policy CoinBirexy was developed on the basis of the current legislation of the host country of the digital service.

1.b Service CoinBirexy is an online resource for exchanging digital coins, even available on the mobile app. exchange address - https://testformyproject.xyz/.

1.c Conditions for the user. The user of the service can be a citizen who has reached the age of 16 or an adult who must provide documentary evidence of age in case of exchange request. In case of violation of the established rules, the user is obliged to immediately stop all ongoing operations, exit the site or close the application.

1.d An AML Policy is a set of internal provisions and rules developed by the service CoinBirexy. These rules are guided by conducting audits and disclosing documentation relating to monetary cryptocurrency transactions. Mandatory control is subject to transactions relating to property, which may be related to legalization or sponsoring terrorist activities. Upon detection suspicious transactions information is provided to government organs.

Service CoinBirexy is based on the principles of transparency and following the letter law. Existing regulations aim to prevent legalization funds obtained by fraudulent means or illegal operations carried out through the functionality of the digital service. Rules apply to all users who spend any money transactions via CoinBirexy.

1.e The AML document (Policy) is intended for:

  • regulation of organizational work aimed at preventing legitimizing illegal money and sponsoring a terrorist activities;
  • establishing responsibilities for service employees and rigorous implementation of procedures that are adopted in terms of internal control;
  • marking the deadlines for the fulfillment of obligations by employees and the appointment of persons authorized to control the process.

1.f The following programs are included in the AML Policy:

  • review of internal control methods;
  • introducing new ways for internal control;
  • performing the identification of customers and persons using the online exchanger;
  • to investigate possible risks;
  • regulating commercial relations between the service and the client;
  • providing blocking actions provided by the software regulations upon detection of suspicious transactions carried out with the purpose of legalizing cryptocurrencies obtained by criminal means;
  • responsible for the exchange of correspondence;
  • documenting information;
  • transaction denial;
  • training new employees CoinBirexy;
  • internal control;
  • on maintaining control over documentation that appears when performing internal control actions.

1.g The Director is responsible for implementing the internal Service Policy CoinBirexy.

2. Basic provisions for the organization of control methods

2.a To implement and implement the AML Policy in full, given the number of users of the digital service and the increasing this number of risks, administration CoinBirexy a working group. It included several people - the head of the department security, administrators and accountant.

2.b Initial client recognition and application questions measures in case of difficulties with identification will be dealt with Service employees whose duties include such a range of tasks.

2.c The following requirements apply to the person referred to in point 1.g of the domestic policy:

  • analyze transactions that have already been made on the service, or only planned for money laundering or financing illegal terrorist groups;
  • provide finance inspectorates with all available data on users conducting suspicious money transactions that may be associated with illegal activities;
  • submit progress reports;
  • Fulfill the obligations set by the anti-money laundering and anti-financial terrorism authority.

3. Implementation of controls

3.a The use of control methods is relevant in the following cases:

  • when a commercial relationship is established with the client and when he performs actions on the service;
  • mandatory if transactions are over EUR 15,000 or equivalent in any other currency;
  • when there is doubt about the reliability or accuracy of the data provided by the user;
  • when the planned transaction is highly complex;
  • if you suspect that a monetary transaction is related to money laundering, intended to finance terrorism, associated with other forms of illegal activity, has a high the risk indicator indicated by the risk assessment analysis, approved by the Service policy;
  • if an automated AML system that checks online wallet of the client, will detect a possible connection with dubious organizations – Illegal Service, Darknet Marketplace, Mixing Service, Ransom, Fraudulent Exchange, Stolen Coins, Darknet Service, Scam.

If the connection between the user and the listed organizations will be confirmed, the operation is canceled, the funds are returned to the sender back (minus a commission of 10%) as soon as the User will be verified.

3.b Additional controls apply if the User changes the conditions or details of currency exchange, partially fulfills or does not fulfills them, which leads to an increase in the risk level of the transaction:

  • the exchange does not serve a reasonable purpose;
  • financially exchange operation is inexpedient;
  • the same financial transaction is carried out several times in a short period of time;
  • The user ignores the requirements of the Service to provide additional information provided for by the rules and policies of work to CoinBirexy, does not indicate the reasons for the refusal or makes no claims to privacy of user data;
  • The user changes the transaction method, which is atypical and is practiced in exchange operations;
  • unreasonable haste in performing an operation or exchanging a User;
  • on the eve of the transaction or exchange, the User changes the conditions for the manipulation;
  • there is no feedback from the User, he does not respond to telephone calls, e-mails and other specified contacts;
  • there are grounds to suspect that the information provided by the client is untrue, inaccurate or false;
  • the scheduled operation (exchange/transaction) will go too far the economic reason for such a process is difficult and cannot be traced.

3.с Additional controls are applied to suspicious transactions:

  • Additional information and explanations are required from the customer, indicating the purpose of the exchange operation or transaction;
  • Increased monitoring provided by internal policy, which concerns all transactions of the User for the purpose of confirmation/denial direct or indirect connection of the transaction with money laundering and / or financing terrorist organizations.

4. Program for the identification of users and persons associated with them

4.a The primary authentication of the client is carried out according to the data provided by him or documents confirming his identity.

4.a.1 To identify the User, they resort to the use software from the partner site, which is specified in the Rules CoinBirexy and does not violate the Privacy Policy.

4.а.2 The Client who uses the services of the Service must provide the following data:

  • Name (last name, first name, patronymic);
  • citizenship to a country;
  • date of birth, identification code;
  • information on the document that certifies the identity;
  • actual place of residence;
  • individual taxpayer number (if any);
  • type of employment (who works);
  • contact details - phone, email address.

4.a.3 The verification process checks the validity of the information provided in the documents and the following research:

  • the authenticity of the document and the photo on it is checked;
  • correspondence of the identification code to age and gender;
  • The validity of the submitted document is verified through the government agencies that issued the identity card.

4.а.4 From the document provided by the User confirming personality, a high-quality copy is made, on which all data.

4.a.5 In parallel with confirming the identity of an individual, it is checked whether it belongs to officials:

  • civil servants are persons who hold public positions in the EU countries and / or other states, or persons holding high positions in international organizations, if a person turns out to be a civil servant, then data is collected about his type activities;
  • publicly available data about closest associates, relatives are collected;
  • Income and ownership are checked to ensure confirmation of the legality of the funds used in the exchange or transaction;
  • a query is sent to the database to verify the income information;
  • a request is being prepared to the state supervision authorities;
  • a decision is made to grant the opportunity to use service, to a person who is a civil servant, the decision to start commercial relations is adopted by a group that is established by an internal Service Policy (clause 2.a).

4.а.6 Only official sources are used for verification information - state registries and / or state government bodies other countries. The use of other sources of information is appropriate if there are no questions about their reliability or competence.

4.a.7 If a new client was recommended by a User with good reputation on the service, this is not a reason to cancel the check.

4.a.8 The User Representative is subject to the same identification individual as well as the client. Verification is carried out on the basis of the Rules Service and Personal Identification Policy.

4.a.9 Identity authentication occurs more than once. Actual user information should be checked constantly and updated when changes.

4.b Documentation provided by foreign countries, submitted in original form with an apostille. The exception is the documents of Lithuania, Ukraine, Russia, Latvia, Poland. Changes in which the apostille is not will be mandatory if the host country of the digital Service will make a new approval and ratify the treaty at the international level.

4.c If there is reason to believe that the risk of surgery will be low, client identification is carried out according to a simplified scheme. For verification uses data from their public databases, which considered as reliable. Conducted analysis for determination level of risk is not the only reason for determining a trade low-risk.

The operation may not require careful review if the client resides in the host country of the digital Service or another country with robust anti-money laundering system regulated by legislative level. With a simplified verification system, the company is obliged to check the transparency of the transaction.

4.d When there is a high level of risk or there is a reason indicating for a possible increase in risks, more stringent controls are applied to user identification.

For this purpose, additional documents are requested from the client and information, the presence of which can reduce your risks. Information must be submitted to the financial inspectorate of the host country digital Service for instructions. In addition to the above factors, a transaction may be recognized as high-risk if:

  • deal terms are unusual;
  • client manages large amounts of cash;
  • the subjects of the transaction are previously unknown, new goods, the specifics of the transaction are atypical;
  • the purpose of transactions is anonymity;
  • payments are made by unknown third parties after the transaction;
  • circumstances provided for in section 37 of the Money Laundering Act in host country of the digital Service and the Law on Prevention financing of terrorism.

4.e The high-level control method is not applied in case of provision by the Bureau for the Prevention of Money Laundering host country of the digital Service of special permission.

4.f Without prior permission from the Money Laundering Prevention Bureau, high-risk transactions are not possible.

5. Risk Assessment

Each User and his transaction undergoes an assessment of financial (money laundering) and client (terrorism financing) risks.

5.a.1 After conducting a relative risk analysis, The User receives a status in the range of the lowest - the highest.

5.а.1 The following factors are taken into account in the risk analysis:

  • The user is a civil servant or is associated with a civil servant;
  • if the recipient/beneficiary from an individual is a third party;
  • if there are problems with identification;
  • the connection between the User and low-tax jurisdictions is traced;
  • The user is under international sanctions;
  • the presence of a positive User experience with the service;
  • the duration of creating an account on the Service is taken into account;
  • type of planned transaction;
  • amount;
  • User's stability, his exchange operations are permanent;
  • doubtful origin of property and/or goods.

5.b The nature of the transaction is required to be assessed when setting the risk status.

5.b.1 A low, medium, or high status is assigned to an exchange if:

  • the bank participates in the exchange operation;
  • transaction involves different payment methods;
  • The exchange is related to gambling.

5.с Geographic risk assessment.

5.c.1 Geographical factors influence the assignment of low, medium or high risk status:

  • the exchange is made by the User and/or is associated with a country where there is a high level of crime and drug trafficking;
  • the party to the exchange is a User who is a citizen of a country with a high level of corruption;
  • The user is a citizen of a country subject to international sanctions;
  • Other reasons that increase geographic risk.

5.d An assessment of the risks associated not only with the User, but also with his partners/relatives is carried out.

5.e Each group of related people is checked separately and scored from 1 to 10 points:

  • low status is assigned if the exchange is transparent and the groups of people being tested have no risk aspects;
  • medium is set when there are no obvious risk factors for the transaction, but due to a combination of factors, there are suspicions about the legalization of money, obtained by criminal means and/or sponsoring terrorism;
  • High status is given to non-transparent transactions and a combination of several aspects of risk.

All the results obtained in the evaluation of groups of people associated with By the user, are summarized. Risks calculated separately for partner and client are doubled and the amount received is divided by 4:

  • if the calculation result is 2 or lower, it is low risk;
  • sum 2-2.75 - average;
  • from 2.75 - high.

If the risk score in any one category is high, then the entire the trade is assigned a high risk status regardless of the calculation overall result.

6. Contractual relationship with the User

6.а Commercial relations between the Service and the User enter into force after the latter agrees with the Rules and internal Service AML Policy.

7. Measures to be taken when there is suspicion of money laundering and obligation to provide information.

7.a If before the start of cooperation or during the verification process there will be suspicions that transactions are related to sponsorship terrorism and/or money laundering, any commercial the relationship ends.

7.b Suspicions are subject to registration and careful analysis contact person. The received data is transferred to the Financial Inspectorate the country of location of the digital Service and the Bureau for Combating Illicit legalization of money.

7.c All information on transactions with an amount of 32,000 euros and more must be submitted to the regulatory authorities.

7.d In case of damage to the client or arrest of a person (if suspected terrorist financing or money laundering money) caused by the failure of the transaction, the exchange operation postponed or implemented, but with mandatory information Financial inspections.

7.f Following the Privacy Policy and the internal policy of the Service, all data that is transmitted to the Financial Supervision Authority is stored in archive.

7.f Persons suspected of using service in dishonest transactions, do not receive information about the occurrence suspicion.

8. Correspondence

8.a For more accurate information, the management of the Service may decision to exchange correspondence with third parties (banks, financial institutions).

8.b Correspondence should be exchanged on the basis of a bilateral agreement (as a method of control).

8.c it is forbidden to exchange correspondence with organizations that do not have licenses or shadow banks. Exchange is not allowed with organizations of countries that do not meet established international anti-money laundering and sponsorship standards terrorist activity.

9. Registration information

9.a Behind the information registration program, the employee who conducts exchange, is obliged to draw up a document indicating the specifics of the transaction. In him noted:

  • transaction type, reasons indicating a high risk of the transaction;
  • all exchange data, amount and currency;
  • data about the persons involved in the transaction;
  • data about the methods used to control the transaction.

10. Cancellation

10.a The user is denied a transaction if he does not provides the document requested by the Service, necessary for control.

10.b The exchange is denied if the User cannot document the origin of the money.

10.с stipulated by internal policy, privacy policy and Rules.

10.d When an exchange is refused, the following information is stored:

  • reasons for blocking an account and refusing to exchange;
  • reasons for termination of cooperation in the field of exchange;
  • data that became the basis for reporting to government agencies, specified in section 32 of the Money Laundering Prevention Act and sponsoring terrorism.

10.с The decision to refuse the exchange is canceled if:

  • the client will provide the requested information in full;
  • new documents are being reviewed;
  • the corresponding decision was made by the competent court or regulatory authority of the country where the digital Service is located.

11. Employee training CoinBirexy

11.а The program for training employees to work with the identification of actions money laundering and terrorist financing provided for a month. Authorized employees instruct workers. The program is conducted in accordance with the laws of the country finding a digital Service and includes instructions for conducting checks and methods of data analysis.

12. Review of internal controls

12.a The internal control program ensures compliance with employees of the Service of the current provisions of the law, aimed at countering the laundering of money received fraudulently, and sponsoring terrorism. Service employees are violate the rules and regulations in the field of internal control.

12.b Internal controls include:

  • at least once every 6 months, internal checks are carried out for proper implementation of the rules of the Service and compliance with legislative norms;
  • all information about violations of internal regulations relating to money laundering and countering the sponsorship of terrorism should be provided to the Service Director;
  • Measures are taken to eliminate the identified violations with the help of levers of influence chosen by the Service management.

13. Document Services Program

13.a All documentation related to the identification process User, at the beginning of cooperation with the Service, is stored in the archive on throughout the partnership between the exchanger and the client and after. Shelf life - up to 5 years.

13.b Documents that were provided to government agencies are kept for up to 5 years.

13.c Data on requests that were made to comply with the provisions legislation are kept for a period of 5 years. Start of retention period is considered from the date of financial cooperation between the parties. At identification of an individual through a digital document, signature and photograph is in the archive 5 years from the date of termination of financial cooperation.

13.d The form in which records are retained must provide for its written reproduction so that data can be quickly provided upon request government agencies that control financial flows, if information is needed for submission in civil, criminal or arbitrary judicial proceedings.

Secrecy standards are created according to internal control rules data that is obtained in the process of user identification and comply with applicable law.

14. Requirements of the judiciary

Any organizations that fight against illegal money laundering money obtained by fraud or sponsorship of terrorism, has the right to send us transaction requests to our e-mail. Contact email [email protected].

Requests are subject to consideration only on official forms with all necessary signatures and seals. To request must contacts for feedback are attached. Contact details are also important. to validate the request. While processing requests from different law enforcement agencies are affected by different circumstances - sentries belts, the possibility of fast communication channels, distance and other factors.