AML POLICY DISCLAIMER
Transactions with Cryptocurrencies involve various risks, including the risk of money laundering and terrorist financing. For this reason, Connectee has implemented Anti-Money Laundering and Counter Terrorist Financing Compliance Guidelines (‘Guidelines’) and undertakes measures for the prevention of Money Laundering and Terrorist Financing.
Beneficial Owner
Beneficial Owner is a natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or exercises control in another manner over a transaction, act, action, operation or step or over another person and in whose interests or for whose benefit or on whose account a transaction or act, action, operation or step is made. In the case of a legal entity, the Beneficial Owner is a natural person whose direct or indirect holding, or the sum of all direct and indirect holdings in the legal person, exceeds 25 percent, including holdings in the form of shares or other forms of bearer.
Money laundering
Money Laundering (ML) is the concealment of the origins of illicit funds through their introduction into the legal economic system and transactions that appear to be legitimate. There are three recognized stages in the Money Laundering process:
Terrorist financing
Terrorist Financing (TF) is the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism in the meaning of applicable legislation.
Customer due diligence measures
Customer due diligence (CDD) measures are required for verifying the identity of a new or existing User as a well-performing risk-based ongoing monitoring of the business relationship with the User. Connectee takes various measures during and after the KYC verification, which consist of 3 levels, including simplified and enhanced due diligence measures, which will be implied by Connectee in accordance with the identified risk level of the User.
Connectee will identify the User, their representative (incl. their right of representation), as well as any other connected persons, where relevant. For this, Connectee may collect and retain from the User various documents and data for the following purposes:
Sanctions
Sanctions are an essential tool of foreign policy aimed at supporting the maintenance or restoration of peace, international security, democracy and the rule of law, following human rights and international law or achieving other objectives of the United Nations Charter or the common foreign and security Policy of the European Union.
Upon the entry into force, amendment or termination of sanctions, Connectee will verify whether the User, the Beneficial Owner or a person who is planning to have the business relationship or transaction with them is a subject of Sanctions. When identifying the subject of the Sanctions, Connectee will identify the measures that are taken to Sanction this person in order to take appropriate measures against such person.
Reporting obligation
Where Connectee suspects that a User is involved in any money laundering, terrorist financing, other illegal activities or transaction(s) exceed the thresholds set by the applicable law, Connectee will report any relevant knowledge or suspicion to the relevant governmental and regulatory authorities. Connectee is prohibited to inform a person, its Beneficial Owner, representative or third party about a report submitted on them to the relevant regulatory authority, a plan to submit such a report or the occurrence of reporting as well as about a precept made by the relevant regulatory authority or about the commencement of criminal proceedings.
Data retention
Connectee collects and retains documents and data about the User and their transactions and other activities during and after the KYC verification, in the course of monitoring the business relationship (also incl. any instances, where Connectee was not able to implement CDD and circumstances of the termination of a business relationship). Connectee also retains data related to the reporting obligation and the correspondence of a business relationship with the User. All data is retained in accordance with the minimum retention periods set by the applicable law.
Internal control
Connectee conducts periodic internal control of the performance of the Guidelines.
Transactions with Cryptocurrencies involve various risks, including the risk of money laundering and terrorist financing. For this reason, Connectee has implemented Anti-Money Laundering and Counter Terrorist Financing Compliance Guidelines (‘Guidelines’) and undertakes measures for the prevention of Money Laundering and Terrorist Financing.
Beneficial Owner
Beneficial Owner is a natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or exercises control in another manner over a transaction, act, action, operation or step or over another person and in whose interests or for whose benefit or on whose account a transaction or act, action, operation or step is made. In the case of a legal entity, the Beneficial Owner is a natural person whose direct or indirect holding, or the sum of all direct and indirect holdings in the legal person, exceeds 25 percent, including holdings in the form of shares or other forms of bearer.
Money laundering
Money Laundering (ML) is the concealment of the origins of illicit funds through their introduction into the legal economic system and transactions that appear to be legitimate. There are three recognized stages in the Money Laundering process:
- placement, which involves placing the proceeds of crime into the financial system;
- layering, which involves converting the proceeds of crime into another form and creating complex layers of financial transactions to disguise the audit trail and the source and ownership of funds;
- integration, which involves placing the laundered proceeds back into the economy to create the perception of legitimacy.
Terrorist financing
Terrorist Financing (TF) is the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism in the meaning of applicable legislation.
Customer due diligence measures
Customer due diligence (CDD) measures are required for verifying the identity of a new or existing User as a well-performing risk-based ongoing monitoring of the business relationship with the User. Connectee takes various measures during and after the KYC verification, which consist of 3 levels, including simplified and enhanced due diligence measures, which will be implied by Connectee in accordance with the identified risk level of the User.
Connectee will identify the User, their representative (incl. their right of representation), as well as any other connected persons, where relevant. For this, Connectee may collect and retain from the User various documents and data for the following purposes:
- identification of the User, who is a natural person (the User, who is natural person, cannot use a representative in the course of business relationship or occasional transaction with Connectee);
- identification of the User, who is a legal entity;
- identification of the User's representative and their right of representation (incl. the nature and scope of the right of representation of the User);
- identification of the User's Beneficial Owner;
- identification, whether the User, the Beneficial Owner of the User or the representative of this User is a politically exposed person, their family member or close associate or if the User has become such a person;
- understanding the purpose and nature of the establishing business relationship or performing transaction;
- monitoring of the business relationship (incl. updating the documents and data collected during the KYC verification, screening and monitoring of the transactions of the User concluded during the business relationship, identification of the source and origin of the funds used in the transaction).
- Connectee is not able to take and perform any of required CDD measures;
- Connectee has any suspicions that Connectee’s services or transaction will be used for Money Laundering or Terrorist Financing;
- the User which capital consists of bearer shares or other bearer securities;
- the User who is a natural person behind whom is another, Beneficial Owner, wants to establish the business relationship (suspicion that a front person is used);
- the risk level of the User or of the transaction does not comply with Connectee's risk appetite.
Sanctions
Sanctions are an essential tool of foreign policy aimed at supporting the maintenance or restoration of peace, international security, democracy and the rule of law, following human rights and international law or achieving other objectives of the United Nations Charter or the common foreign and security Policy of the European Union.
Upon the entry into force, amendment or termination of sanctions, Connectee will verify whether the User, the Beneficial Owner or a person who is planning to have the business relationship or transaction with them is a subject of Sanctions. When identifying the subject of the Sanctions, Connectee will identify the measures that are taken to Sanction this person in order to take appropriate measures against such person.
Reporting obligation
Where Connectee suspects that a User is involved in any money laundering, terrorist financing, other illegal activities or transaction(s) exceed the thresholds set by the applicable law, Connectee will report any relevant knowledge or suspicion to the relevant governmental and regulatory authorities. Connectee is prohibited to inform a person, its Beneficial Owner, representative or third party about a report submitted on them to the relevant regulatory authority, a plan to submit such a report or the occurrence of reporting as well as about a precept made by the relevant regulatory authority or about the commencement of criminal proceedings.
Data retention
Connectee collects and retains documents and data about the User and their transactions and other activities during and after the KYC verification, in the course of monitoring the business relationship (also incl. any instances, where Connectee was not able to implement CDD and circumstances of the termination of a business relationship). Connectee also retains data related to the reporting obligation and the correspondence of a business relationship with the User. All data is retained in accordance with the minimum retention periods set by the applicable law.
Internal control
Connectee conducts periodic internal control of the performance of the Guidelines.