AML/KYC

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Introduction

This document gives an overview of the standards of the “Know Your Customer” and “Anti-Money Laundering” policies, thereby setting our practices for the prevention of money-laundering activities while dealing with our users.

The objective of AML/KYC Policy is to prevent CoinFit from being used, intentionally or unintentionally, by criminal elements for money-laundering activities. The Policy also mandates making reasonable efforts to determine the true identity and beneficial ownership of accounts, source of funds, the nature of customer’s business, the reasonableness of operations in the account in relation to the customer’s business, etc., which in turn helps us to manage its risks prudently.

We strive to protect our customers from fraudulent and scam activities in the crypto assets sphere. CoinFit employs a steadfast approach in the implementation of the latest recommendations and revised guidelines by FATF, European Parliament, and regulators of the financial industry by and large. Our in-compliance policy stance is designed to detect funds proven to be involved in illicit activities as well as to protect the funds of our customers who have fallen victims to hacks, ransomware and malware attacks. The toolkit at work committed to fighting money laundering and its implications is comprised of policy regulations in conjunction with recent developments in software aimed at tracking suspicious transactions in real time.

Our AML/KYC Policy, procedures, and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place, to account for both changes in regulations and changes in our business.

1. Customer Identification Procedure (CIP)

CIP applies to transactions that are spotted by our scoring system as suspicious. We will collect certain customer identification information from each customer who passes CIP; utilize risk-based measures to verify the identity of each customer who passes CIP; record customer identification information and the verification methods and results; provide adequate CIP notice to customers that we will seek identification information from to verify their identities.

a. Caution

CoinFit service warns users against attempts to use CoinFit service for money laundering, terrorism financing, fraud of any kind, as well as against using the service for purchasing prohibited goods and services.

CoinFit service, its administration, employees and domain owners are not responsible for misuse of the CoinFit service by third parties, malefactors and possible damages related to the use of CoinFit service.

b. Requirements

  • To prevent transactions of an illegal nature, CoinFit service sets certain requirements for all Applications created by the User:
  • The sender and the recipient of the Payment on the Application must be the same person. Transfers in favor of third parties using the Service are strictly prohibited.
  • All the contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service must be current and fully accurate.
  • It is strictly forbidden to create Applications by the User using anonymous proxy-servers, VPN, Tor or any other anonymous Internet connections.

c. Verification Ptrocedures

  • One of the international standards for the prevention of illegal activities is customer due diligence (hereinafter – Verification). To this end, CoinFit implements its own verification procedures in strict anti-money laundering standards and a procedure «Know Your Client».
  • The CoinFit Service may require the User to provide the CoinFit Service with reliable, independent source documents, data or information (e.g., national ID card, international passport, bank statement). For such purposes, the CoinFit Service reserves the right to collect User identification information for purposes of compliance with the AML/KYC Policy.
  • CoinFit Service will take steps to verify the authenticity of documents and information provided by Users. All legal methods to double check identifying information will be used, and the CoinFit Service reserves the right to investigate cases of certain Users whose identities have been determined to be dangerous or suspicious.
  • CoinFit Service reserves the right to verify the User's identity on an ongoing basis, especially when his/her identification information has been changed or his/her activity seems suspicious (unusual for a particular User). In addition, CoinFit Service reserves the right to ask Users for up-to-date documents, even if they have been authenticated in the past.
  • User identification information will be collected, stored, shared and protected strictly in accordance with the CoinFit Service Privacy Policy and related policies.
  • After confirmation of the User's identity, CoinFit Service may refuse to provide services to the User in a situation where the CoinFit Service is used to conduct illegal activities.
  • Users who intend to use payment cards for the purpose of consuming services must complete card verification according to the instructions available at CoinFit.org
  • CoinFit Service has regulatory requirements to verify the source of funds or cryptocurrency to know that the sources of funds that Users use to trade are legitimate.

d. Responsible officer

  • The AML Compliance Officer is the person duly authorized by the CoinFit Service whose responsibility it is to ensure that AML/KYC policies are effectively implemented and enforced.
  • It is the responsibility of such officer to oversee all aspects of CoinFit's anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods: collection of user identification information;
    • create and update internal policies and procedures for completing, reviewing, submitting and maintaining all reports and records required by applicable laws and regulations;
    • monitoring transactions and investigating any significant deviations from normal activity;
    • implementation of a records management system for proper storage and retrieval of documents, files, forms and journals;
    • regular updating of the risk assessment;
    • providing law enforcement agencies with the information they need under applicable laws and regulations.
  • The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

2. System functions

  • The CoinFit service performs many compliance-related tasks, including data collection, filtering, record keeping, investigation management and reporting. System functions include:
  • checking Users daily for the existence of recognized «blacklists» (e.g. OFAC), aggregating transmissions across multiple data points, placing Users on watch and denial of service lists, opening cases for investigation where appropriate, sending internal communications and completing mandatory reports, if applicable;
  • case and document management.

3. Behavior Analysist

CoinFit Service verifies Users not only by checking their identity, but more importantly, by analyzing their behavior in transactions. Therefore, CoinFit Service relies on data analysis as a risk assessment and suspicion detection tool.

4. Risk scores

CoinFit, in line with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, CoinFit ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified.

5. Performing customer checks

  • In case the CoinFit administration suspects that a user is attempting to use the service for illegal activities, the AML Officer is entitled to:
  • suspend the user's exchange operation;
  • ask the User for documents identifying him/herself;
  • request any additional information and documents from the user related to suspicious transactions, without providing an explanation of the reasons;
  • ensure that reports of the suspicious nature of transactions are relayed to appropriate law enforcement agencies through the AML compliance officer.

6. Privacy

  • CoinFit service guarantees customer privacy in accordance with the privacy policy of the service.
  • The CoinFit Service and its employees are obliged to maintain confidentiality regarding any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom information on the transaction has been transmitted.
  • The obligation of confidentiality imposed on CoinFit Service employees shall survive the termination of their employment or any other contractual relationship with CoinFit Service or the transfer of such employees to another workplace. Disclosure of such information to governmental, law enforcement or other entities as permitted by law does not constitute a breach of the obligation of confidentiality.
  • The obligation of confidentiality, provided that the use of disclosed information is limited to preventing the legitimization of proceeds of crime and terrorist financing, may not apply to disclosures between financial institutions that form a consolidated group that cooperates with the CoinFit Service.

7. Conclusion

Therefore, CoinFit Service shall not be held legally responsible for its use for money laundering, terrorist financing or prohibited goods and services purchase purposes, but shall take all possible and available actions to prevent any attempts to use the CoinFit Service for money laundering, terrorist financing or prohibited goods and services purchase purposes.

By making the exchange, the User agrees to point 13.5. of Terms of use to all of the terms of these policies and agrees to abide by them.