The purposes of the ALTEWAY (hereinafter in the text Company or Alteway) Anti-Money Laundering, Counter-Terrorist Financing and Know Your Client Policy (hereinafter — the “AML/CTF and KYC Policy”) is to identify, prevent and mitigate possible risks of Alteway being involved in illegal activity.
To confirm with international and local regulations, Alteway has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users.
Anti-money laundering (AML) refers to the laws, regulations and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
Combating the Financing of Terrorism (CFT) is a set of government laws, regulations, and other practices that are intended to restrict access to funding and financial services for those whom the government designates as terrorists. By tracking down the source of the funds that support terrorist activities, law enforcement may be able to prevent some of those activities from occurring.
All firms must adhere to the Money Laundering, Terrorist Financing and the recommendations from the Financial Action Task Force (FATF), an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.
AML/CFT and KYC Policy includes:
– Verification procedure;
– The Compliance Person;
– Transactions Monitoring;
– Risk Assessment;
– Risk categories.
To help fight the funding of terrorism and money laundering activities, the Law requires all financial institutions to obtain, verify and record information that identifies each person or entity who opens an Account. We are required by Law to ask you to provide your name, address, date of birth and other information about you, your organization or persons related to your organization that will allow us to identify you before we approve your Account. We also may ask you to provide certain identifying documents, such as your driver’s license or passport or your organization’s articles of incorporation and may obtain credit and other consumer reports to assist us in verifying your identity and in determining whether you satisfy our account criteria. Unless you provide the requested information and documentation, we may not be able to open your Account.
By applying for an Alteway Account, you agree to provide the information and documentation requested by Alteway and consent to Alteway acquisition of credit and other consumer reports about you for the purposes described above.
The Alteway User due diligence (“CDD”) procedure requires the Users to provide Alteway with reliable, independent source documents to identify them and confirm their residential address. Such documents may include, for example, a national ID card, an international passport, a bank statement, a utility bill. For such purposes, Alteway reserves the right to collect the Users’ identification information for the purposes of compliance with its AML/CFT and KYC Policy.
Alteway will take steps to confirm the authenticity of documents and information provided by Users. Alteway will also look to verify identification information through secondary sources, and reserves the right to investigate further the cases of Users where Alteway is not satisfied with the documentation submitted.
Alteway reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, Alteway reserves the right to request from the Users current documents, even if they have been authenticated in the past.
After confirming the identity of the user, Alteway may refuse to provide Services to the User if Alteway Services are suspected to be used for the purposes of conducting illegal activities.
Alteway has a regulatory requirement to verify the sources of Fiat Money and/or Cryptocurrency to know that the sources of the Funds that Users use to trade with are legitimate. Alteway will require evidence of the source of Funds; this may include bank statements for Fiat Money or a video showing wallet transaction details for Cryptocurrency.
Users who intend to use payment cards for the purpose of consuming Services must undergo a card check in accordance with the instructions available on the Alteway Site.
Alteway uses independent third-party companies for the following:
– check Users against Politically Exposed Person’s (PEP) and Sanctions Lists.
– assess User’s cryptocurrency wallets with regards to AML investigation and compliance.
Alteway reserves the right to terminate or refuse Accounts on the basis of information attained by the third-party companies this includes Users connected to “high-risk” wallets.
THE COMPLIANCE PERSON
The Compliance Person is duly authorized by Alteway, whose duty is to ensure the effective implementation and enforcement of the AML/CFT and KYC Policy. It is the Compliance Person responsibility to supervise all aspects of Alteway anti-money laundering and counter-terrorist financing procedures, in particular:
– collection of Users’ identification information;
– 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;
– monitoring transactions and investigating any significant deviations from normal activity;
– implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs, updating risk assessment regularly, providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Person is the contact point for Alteway with law enforcement agencies for the purposes of prevention of money laundering, terrorist financing and other illegal activities.
Alteway Users must complete the Alteway identity verification process (who you are) before trading. After verification is completed the User consents to transaction Monitoring, Alteway analyses User’s transactional patterns (what they do).
Alteway relies on data analysis as a risk-assessment and suspicious activity detection tools. These tools perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting.
In connection with the AML/CFT and KYC Policy, Alteway will:
– monitor all transactions. Alteway reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement;
– request the User to provide any additional information and documents in case of suspicious transactions;
– suspend or terminate work with a client if there is reasonable suspicion that such a client is engaged in illegal activities.
However, the above list is not exhaustive and the Compliance Person will monitor Users’ transactions on a regular basis in order to define whether such transactions are to be reported and treated as suspicious.
The European Union adopted robust legislation to fight against money laundering and terrorist financing which contributes to those international efforts. The Commission ensures effective application of this legislation by reviewing transposition of EU acquis and working with networks of competent authorities.
Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) constantly assessing compliance with the principal international standards to counter money laundering and the financing of terrorism and the effectiveness of their implementation, and make recommendations to national authorities in respect of necessary improvements to their systems, also conducts thematic typologies research of money laundering and terrorist financing.
FATF continuously monitors the new or developing methods that criminals use to launder the proceeds of their crimes, and how terrorists raise, use and move the funds they need. FATF typologies reports aim to raise awareness with authorities as well as the private sector about the risk of particular sectors or products, so that they can take appropriate actions to mitigate these risks.
In order to meet its obligations regarding Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) Alteway completes an annual AML Risk Assessment. The aim of the AML Risk Assessment is to prevent criminals using Alteway to launder money by highlighting risks and assessing controls Alteway has put in place. A risk-based approach is taken to identify Users and monitor how they use our Services.
The Compliance Person is responsible for managing financial crime risks and making improvements in financial crime risk management through identifying the general and specific money laundering risks that Alteway is facing, determining how these risks are mitigated by the Alteway AML controls and establishing the residual risk that remains for Alteway.
RISK BY USERS:
Suspicious facts such as but not limited to the: discrepancies in provided id documents, fictitious person, stolen identity, counterfeited id document, post box home address, pervious financial crime record, terrorist record, wanted person, no contact phone number, not valid documents, discrepancies in provided documents for the legal person, etc.
Politically exposed persons such as but not limited to the: prominent public functions: head of state, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a state-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials.
RISK BY COUNTRIES:
EU policy on high-risk third countries based on Directive (EU) 2015/849, Article 9, the Commission is mandated to identify high-risk third countries having strategic deficiencies in their regime on anti-money laundering and countering the financing of terrorism. The aim is to protect the integrity of the EU financial system.
5th Anti-Money Laundering Directive ((EU) 2018/843) imposes stricter due diligence requirements for business relationships or transactions that involve high-risk third countries. These include requirements to obtain additional information on the customer and beneficial owner, sources of funds and wealth, reasons for the transaction as well as a requirement to obtain senior management approval in order to establish or continue the relationship. The Directive also contemplates that Member States may impose additional restrictions on conducting business relationships.