This Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate risks of Coingrab OÜ related to money laundering and associated risks. This is a short extract of key principles of the internal Policy and should not be seen as a complete document. You can request the full document by contacting customer support of the Company. Domestic and international regulations require Coingrab OÜ to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Customers.
Before the company can execute any transaction for any new Customer, a number of procedures need to be in place and carried out:
Whenever the company receives supporting documents related to a new Customer’s identity, it needs to be completely satisfied that they demonstrate the existence of the new Customer as a real natural or legal person and that they are indeed whom they say they are. Although the company will at times rely on third party sources as part of its factchecking procedure when on boarding Customers, the company bears ultimate legal responsibility for the checks being satisfactory.
Customer’s identification information will be collected, stored, shared and protected strictly in accordance with the company’s Privacy Policy and related regulations that correspond to the GDPR requirements.
AMLRO is ultimately responsible for implementing the regulations concerning AML.
As noted above, the AMLRO is a person of authority with access to any and all relevant information for the completion of his duties.
The constant monitoring of the Customers’ accounts and transactions is an imperative element in the effective controlling of the risk of Money Laundering and Terrorist Financing.
In this respect, the AMLCO shall be responsible for maintaining as well as developing the on-going monitoring process of the company.
The company shall apply appropriate measures and procedures, by adopting a risk-based approach, so as to focus its effort in those areas where the risk of Money Laundering and Terrorist Financing appears to be comparatively higher.
Further, the AMLRO shall monitor and evaluate, on an on-going basis, the effectiveness of the measures and procedures of this Policy.
The adopted risk-based approach that is followed by the company, and described in the Policy, has the following general characteristics:
The risk-based approach adopted by the company, and described in the Policy, involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the Money Laundering and Terrorist Financing risks faced by the company.
The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions.
The Company does not provide services to persons residing in countries that:
Full list of such countries is available in the full version of the Anti-Money Laundering Policy and can be accessed by requesting the same from Coingrab OÜ. Company reserves the right to update this list by the decision of the AMLRO having effect prior to updating of this document.