Anti-Money Laundering and Know Your Customer Policy.
The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) is aimed at preventing and mitigating potential risks associated with MOST.Exchange’s involvement in illegal activities. In accordance with international and local legislation, MOST implements effective internal processes and tools to combat money laundering, terrorist financing, human and drug trafficking, proliferation of weapons of mass destruction, corruption and bribery, as well as to respond to possible cases of suspicious activity by users.
The AML/KYC Policy includes the verification process, the presence of an employee in the company responsible for AML compliance, transaction monitoring and risk assessment. One of the international standards for preventing illegal activities is customer due diligence (CDD). Therefore, MOST.Exchange implements its own verification procedures within the framework of strict anti-money laundering and “Know Your Customer” policies.
MOST’s identity verification process requires the user to provide reliable and independent source documents, data or information (e.g. national ID, international passport, bank statement, utility bill). For these purposes, MOST.Exchange has the right to collect user identification data for the purpose of AML/KYC policy compliance.
MOST will take measures to confirm the authenticity of the documents and information provided by users. All legal means to double-check the identification data will be used, and the company has the right to investigate certain users whose identity may be considered dangerous or suspicious.
MOST reserves the right to regularly verify the user’s identity, especially if their identification information has been changed or their actions seem suspicious (not typical for a particular user). In addition, MOST has the right to request users to provide up-to-date documents, even if they have already been verified.
By verifying the user’s identity, MOST can avoid potential legal liability if the company’s services are used for illegal activities.
The AML Compliance Officer is an authorized representative of MOST whose job it is to ensure the effective implementation and compliance of the AML/KYC policy. This officer oversees all aspects of MOST’s activities to prevent money laundering, including money laundering and terrorist financing, using various methods, such as:
- Collecting user identification data;
- Developing and modifying internal policies and procedures to complete, review, submit and retain all reports and records required by applicable laws and regulations;
- Monitoring transactions and analyzing any significant deviations from normal activity;
- Implementing a data management systеm to properly store and retrieve documents, files, forms and logs;
- Updating risk assessments regularly;
- Referring information to law enforcement agencies in accordance with applicable laws and regulations.
The AML Compliance Officer is authorized to cooperate with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities.
Customers are verified not only through identification, but more importantly, by analyzing their transaction behavior. Thus, MOST relies on data analysis as a tool to determine the level of risk and identify potential problems. MOST performs many compliance-related tasks such as information gathering, filtering, recording, investigation management and reporting. systеm functions inсlude:
- Daily checking users against recognized blacklists (e.g. OFAC), aggregating data from different sources, including users in watchlists and denial of service, initiating investigations when necessary, sending internal messages and generating mandatory reports, if applicable;
- Managing cases and documents.
As part of the AML/KYC policy, MOST will monitor all transactions and has the right to:
- report suspicious transactions to the relevant law enforcement agencies through the AML compliance officer;
- request additional information and documents from the user in case of suspicious transactions;
- suspend or terminate the user’s account if MOST has reasonable suspicions that the user is involved in illegal activity.
The above list is not comprehensive, and the AML compliance officer will review user transactions on a daily basis to determine whether they should be reported and considered suspicious or whether they can be considered bona fide. MOST uses risk assessment methods to combat money laundering and terrorist financing in accordance with international requirements.
Using a risk assessment systеm to prevent money laundering and terrorist financing, MOST strives to implement adequate measures to mitigate these risks.
In the case of cryptocurrencies, MOST has the right to suspend the exchange transaction and request the client to verify his identity in accordance with the rules specified above, as well as documents confirming the origin of the cryptocurrency sent by the client under the exchange request.
If the client refuses to provide verification of identity and documents confirming the origin of the cryptocurrency, MOST conducts an additional investigation until it receives information from law enforcement and regulatory authorities, which may contain instructions regarding the withheld funds.
If the client provides all the necessary documents, MOST undertakes to return the funds or complete the exchange within seven calendar days.
If the funds were placed on exchange wallets and the blocking occurred on the part of the exchange, if the client refuses to undergo verification, the funds remain blocked until the court decides to unfreeze them. In this case, all legal claims of the user should be directed to the source of the blocking of funds – the exchange.
If the court obliges the exchange to return the title signs through the exchange service, the latter returns the funds minus 5-30% of the amount received, as well as other network fees. The percentage of retention depends on the damage caused by the user to the exchange service.