For purposes of this Policy, “us,” “we,” or “our” refer to the company d/b/a Hashing24.
Our Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) are designated to prevent and mitigate possible risks of us being involved in any kind of illegal activity.
Both international and local regulations require us 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 of our customers.
AML/KYC Policy covers the following matters:
The Compliance Officer is the person, duly authorized by us, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of our anti-money laundering and counter-terrorist financing, including but not limited to:
The Compliance Officer is entitled to interact with law enforcement, which are involved in the prevention of money laundering, terrorist financing and other illegal activities.
We, in line with the international requirements, have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, we establish our own verification procedures within the standards of Anti-Money Laundering and “Know Your Customer” frameworks.
a) Identity verification
Our identity verification procedure requires the customer to provide us with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes, we reserve the right to collect customer’s identification information for the AML/KYC Policy purposes.
We will take steps to confirm the authenticity of documents and information provided by the customers. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain customers who have been determined to be risky or suspicious.
We reserve the right to verify a customer’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular customer). In addition, we reserve the right to request up-to-date documents from the customers, even though they have passed identity verification in the past.
Once the customer’s identity has been verified, we are able to remove ourselves from potential legal liability in a situation where our services are used to conduct illegal activity.
b) Card verification
The customers who use payment cards connected with our services can be asked to pass card verification. It may include:
The customers are known not only by verifying their identity (who they are) but, more important, by analyzing their transactional patterns (what they do). Therefore, we rely on data analysis as a risk-assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, recordkeeping, investigation management, and reporting. System functionalities include:
a) A daily check of customers against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing customers on watch and service denial lists, opening cases for investigation if it is essential, sending internal communications and filling out statutory reports, if applicable;
b) Case and document management.
With regard to the AML/KYC Policy, we will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor customers’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.