Anti-Money Laundering (AML) and KYC Requirements
1. Unitech Crypto Ltd Policy Statement
2. AML/CFT Compliance Person Designation and Duties
3. Giving AML/CFT Information to Isle of Man government authorities if requested
4. Levels of Customer Due Diligence (“CDD”)
4.1. People who have opened an account need to provide their full contact details, prior to being allowed to deposit, trade and withdraw currencies. This is known as Level one clearance, which allows deposits and withdrawals of USD 100 a day and USD 1,000 a month.
4.2. Level 2 clearance allows for USD 1,000 a day in deposits and withdrawals and USD 10,000 a month and for this a scanned copy of photographic ID and proof of address as explained in clause 5 is required.
4.3. Level 3 clearance allows for unlimited deposits and withdrawals and for this we will need original certified photographic ID and proof of address in our possession.
5. Customer Due Diligence (“CDD”) and Know Your Client Identification Program (“KYC”)
5.1. Required Customer Information
After opening an account, Unitech Crypto Ltd will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account prior to activating the account for deposits and withdrawals of FIAT currencies (deposits, trading and withdrawing digital currencies does not require CDD verification):
- the name;
- date and place of birth (for an individual);
- phone number;
- proof of a residential address (for an individual), or a principal place of business, local office, or other physical location (for a person other than an individual); and
- proof of identification with a photograph.
5.2. Customers Who Refuse to Provide Information
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Unitech Crypto Ltd will deactivate the account and, after considering the risks involved, consider closing any existing account. In either case, our CCO will be notified so that we can determine whether we should report the situation to the authorities.
5.3. Verifying Information
Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers, but in any case complying with the statutory requirements. The CCO will analyse the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies). We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means, if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer’s name, street address, postcode, email, telephone number, date of birth and photographic ID, allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).
Appropriate documents for verifying the identity of customers include the following:
For an individual
- Proof of identity (passport copy or provisional or full driving license or Government issued National Identity Card (picture page is sufficient));
- Proof of residential address (utility bill* less than 3 months old or bank statement) *Electricity, gas, water, phone bill (not mobile phone).
For a Corporation
- Certificate of Incorporation;
- Memorandum and articles of Association;
- Identify the Beneficial Owner;
- For at least 2 directors of a Corporation – proof of identity and proof of residential address;
- In the case of level three clearance for an individual, we shall request for certification by a lawyer, accountant, or notary public.
The certifier must sign and date the copy document (printing his/her name clearly in capitals underneath) and clearly indicate his/her position or capacity on it and provide his contact details. The certifier must state that it is a true copy of the original. Any non-English documentation requires translation and certification as above. We are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity. We will use the following non-documentary methods of verifying identity: – Confirming validity of email – Confirming validity of telephone number We will verify the information within a reasonable time after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or dollar amount of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with CPY Operation’s CCO, report the activity in accordance with applicable laws and regulations. We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts, such as an account opened in the name of a corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient: 1. Obtain verification of beneficial owners of corporations 2. Obtain additional references from financial institutions.
5.4. Lack of Verification
When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) deactivate the account or keep it in deactivated status; (2) close an account after attempts to verify customer’s identity fail; and (3) determine whether it is necessary to inform the FSC or FSA in accordance with applicable laws and regulations.
We will keep logs of our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain logs that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made.
5.6. Comparison with Government-Provided Lists of Terrorists
At such time as we receive notice that the authorities have issued a list of known or suspected terrorists and identified the list as a list for CDD purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another law or regulation or directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any government agency and designated as such by the authorities in consultation with the functional regulators. We will follow all directives issued in connection with such lists.
5.7. Notice to Customers
We will provide notice to customers that Unitech Crypto Ltd is requesting information from them to verify their identities, as required by law. We will use the following method to provide notice to customers: Inform them by email and through Unitech Crypto Ltd software when the customer wants to activate their account for depositing and withdrawing FIAT currencies, by using the following text:
Important information about procedures for activating a new account:
- To help the government fight the funding of terrorism and money laundering activities, Unitech Crypto Ltd is required to obtain, verify, and record information that identifies each person who opens an account and wishes to deposit and withdraw FIAT currencies.
- What this means for you: When you would like to deposit and withdraw FIAT currencies, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see photographic proof of your identification and proof of address.
6. General Customer Due Diligence
7. Customer Due Diligence and Enhanced Due Diligence Requirements for Politically Exposed Persons
8. Monitoring Accounts for Suspicious Activity
a) Emergency Notification to Law Enforcement by Telephone In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority.
b) Red Flags Red flags that signal possible money laundering or terrorist financing include but are not limited to: Customers – Insufficient or Suspicious Information – Provides unusual or suspicious identification documents that cannot be readily verified. – Reluctant to provide complete information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors or business location. – Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect. – Background is questionable or differs from expectations based on business activities. – Customer with no discernible reason for using Unitech Crypto Ltd service. Efforts to Avoid Reporting and Recordkeeping – Reluctant to provide information needed to file reports or fails to proceed with transaction. – Tries to persuade an employee not to file required reports or not to maintain required records. – “Structures” deposits, withdrawals or purchase of monetary instruments below a certain amount to avoid reporting or recordkeeping requirements. – Unusual concern with CPY Operation’s compliance with government reporting requirements and Unitech Crypto Ltd AML/CFT policies. Certain Funds Transfer Activities – Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent business reason. – Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out in manner inconsistent with customer’s business or history. May indicate a Ponzi scheme. – Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose. Activity Inconsistent with Business – Transactions patterns show a sudden change inconsistent with normal activities. – Unusual transfers of funds or journal entries among accounts without any apparent business purpose. – Maintains multiple accounts or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose. – Appears to be acting as an agent for an undisclosed principal but is reluctant to provide information. Other Suspicious Customer Activity – Unexplained high level of account activity with very low levels of securities transactions. – Funds deposits for purchase of a long-term investment followed shortly by a request to liquidate the position and transfer the proceeds out of the account. – Law enforcement requests.
c) Responding to Red Flags and Suspicious Activity When an employee of Unitech Crypto Ltd detects any red flag, or other activity that may be suspicious, he or she will notify the CCO. Under the direction of the CCO, Unitech Crypto Ltd will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or informing the authorities.
9. Suspicious Transactions Reporting
a) We will file a report with the FSA, or the appropriate regulatory authority for any transactions (including deposits and transfers) conducted or attempted by, at or through Unitech Crypto Ltd involving $10,000 or more of funds (either individually or in the aggregate) where we know, suspect or have reason to suspect: (1) the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade law or regulation or to avoid any transaction reporting requirement under law or regulation; (2) the transaction is designed, whether through structuring or otherwise, to evade any requirements of the regulations; (3) the transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or (4) the transaction involves the use of Unitech Crypto Ltd to facilitate criminal activity. We will also file a report and notify the appropriate law enforcement authority in situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes. We may file a voluntary report for any suspicious transaction that we believe is relevant to the possible violation of any law or regulation but that is not required to be reported by us. It is our policy that all suspicious activities will be reported regularly to the Board of Directors and appropriate senior management.
b) Currency Transaction Reports Unitech Crypto Ltd only allows FIAT currency transactions once accounts are activated. Any transfers over $10,000 may be reported to the authorities.
c) Currency Transportation Unitech Crypto Ltd prohibits both the receipt of currency or other monetary instruments that have been transported, mailed or shipped to us. Unitech Crypto Ltd only accepts currency transactions through financial institutions and internationally recognized payment platforms.
10. AML/CFT Recordkeeping
a) Responsibility for Required AML Records: Our CCO and his or her designee will be responsible for ensuring that AML/CFT records are maintained properly. In addition, as part of our AML/CFT program, Unitech Crypto Ltd will create and maintain all relevant documentation on customer identity and verification (See Section 4 above) and funds transmittals. We will maintain all documentation for at least five years.
b) AML/CFT Reporting Maintenance and Confidentiality: We will hold reports and any supporting documentation confidential. We will not inform anyone outside of the authorities or other appropriate law enforcement or regulatory agency about a report. We will segregate report filings and copies of supporting documentation from other firm books and records to avoid disclosing information. Our CCO will handle all requests for reports.