AML/KYC Policy
Last updated: 11th November 2022
Introduction
Veetrblox Anti-Money Laundering and Know Your Customer Policy (hereinafter -
the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of
Veetrblox being involved in any kind of illegal activity.
Both international and local regulations require Veetrblox 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 Users.
For Law Enforcement requests please direct your official document to our
compliance team here.
AML/KYC Policy covers the following matters:
1. Verification procedures.
2. Compliance Officer.
3. Monitoring transactions.
4. Risk assessment
1. Verification procedures
One of the international standards for preventing illegal activity is customer due
diligence (“CDD”). According to CDD, Veetrblox establishes its own verification
procedures within the standards of anti-money laundering and “Know Your
Customer” frameworks, including enhanced due diligence for customers
presenting a higher risk, such as Politically Exposed Persons (PEPs).
Veetrblox’s identity verification procedure requires the User to provide Veetrblox
with reliable, independent source documents, data or information (e.g., national
ID, international passport, bank statement, utility bill). For such purposes
Veetrblox reserves the right to collect User’s identification information for the
AML/KYC Policy purposes.
Veetrblox will take steps to confirm the authenticity of documents and
information provided by the Users. All legal methods for double-checking
identification information will be used and Veetrblox reserves the right to
investigate certain Users who have been determined to be risky or suspicious.
Veetrblox reserves the right to verify User’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 User). In addition,
Veetrblox reserves the right to request up-to-date documents from the Users,
even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected
strictly in accordance with the Veetrblox’s Privacy Policy and applicable
regulations.
Once the User’s identity has been verified, Veetrblox has no legal liability in a
situation where its Services are used to conduct illegal activity.
Veetrblox is prohibited from transacting with individuals, companies and
countries that are on prescribed sanctions lists. Veetrblox will therefore screen
against United Nations, European Union, UK Treasury and US Office of Foreign
Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.
2. AML Officer
The AML Officer is the person, duly authorized by Veetrblox, whose duty is to
ensure the effective implementation and enforcement of the AML/KYC Policy. It is
the AML Officer’s responsibility to supervise all aspects of Veetrblox’s anti-money
laundering and counter-terrorist financing, including but not limited to:
a. Collecting Users’ identification information;
b. Establishing and updating internal policies and procedures for the
completion, review, submission and retention of all reports and records
required under the applicable laws and regulations;
c. Monitoring transactions and investigating any significant deviations from
normal activity;
d. Implementing a records management system for appropriate storage and
retrieval of documents, files, forms and logs;
e. Updating risk assessment regularly;
f. Providing law enforcement with information as required under the
applicable laws and regulations.
The AML Officer is entitled to interact with law enforcement, which are involved
in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring transactions
The Users are known not only by verifying their identity (who they are) but, more
importantly, by analyzing their transactional patterns (what they do). Therefore,
Veetrblox relies on data analysis as a risk-assessment and suspicion detection
tool. Veetrblox performs a variety of compliance-related tasks, including
capturing data, filtering, record-keeping, investigation management, and
reporting.
System functionalities include:
a. Check of Users against recognized “blacklists” (e.g. OFAC), aggregating
transfers by multiple data points, placing Users on watch and service
denial lists, opening cases for investigation where needed, sending
internal communications and filling out statutory reports, if applicable;
b. Case and document management.
With regard to the AML/KYC Policy, Veetrblox will monitor all transactions and it
reserves the right to:
a. Ensure that transactions of suspicious nature are reported to the proper
law enforcement through the AML Officer;
b. Request the User to provide any additional information and documents in
case of suspicious transactions;
c. suspend or terminate User’s Account when Veetrblox has reasonably
suspicion that such User engaged in illegal activity.
The above list is not exhaustive, and the AML Officer may monitor Users’
transaction behaviour on the on-going basis in order to reach the conclusion
whether such transactions are to be reported and treated as suspicious or are to
be treated as bona fide.
4. Risk assessment
Veetrblox, in line with the international standards, has adopted a risk-based
approach to combating money laundering and terrorist financing. By adopting a
risk-based approach, Veetrblox is able to ensure that measures to prevent or
mitigate money laundering and terrorist financing are commensurate to 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.