In order to comply with the Money Laundering and Terrorist Financing Prevention Act of Estonia (with amendments from 31st of December 2019), requirements of EU AML Directives and best AML/CFT practices, the GEMUL has developed and implemented AML/CFT Program, including Know your customer and Anti-money laundry procedures which are aimed to reduce the risk of being involved in any kind of illegal financial activity. The company’s management deems the task of complying with AML and CFT regulations to be of great importance, thus ensures that the requirements of this Program are met with the highest accuracy
OCCASIONAL TRANSACTIONS AND ANTI-FRAUD MEASURES
The user has an opportunity to perform transactions in the amount limited to the equivalent of EUR 150.00 monthly without establishing business relationships with the Company, using the Company’s website or widget. In this case, relevant data is gathered, and appropriate anti-fraud controls applied to such customers. If the user exceeds limits or the Company management deems it necessary to receive additional information about the transactions – the user will be asked to pass KYC verification.
Additionally, in some cases User might be asked to pass KYC verification in order to perform transaction regardless to its amount as for the amount less than EUR 150.00 as the financial partners of GEMUL might obligate the company to run a due diligence procedure starting from EUR 0.00.
IDENTITY VERIFICATION (KYC)
Strict verification procedures were developed in order to prevent the use of stolen identities or other illegal activity, which may facilitate money laundering or terrorist financing.
In order to pass identity verification, a user must provide personal information, residential address, and upload images of documents that support the provided information. Generally, a driver’s license, a passport, or a national ID card will be provided for this purpose. A recent proof of residence should also be provided to confirm the residential address.
During the KYC verification procedure, the Company is guided by the risk-based approach, so additional information regarding the nature of business relationships and source of funds can be requested from a user.
The information provided by a user is thoroughly checked both automatically and manually in order to confirm the authenticity of the documents.
The company’s AML/CFT measures were developed in order to prevent money laundering activity and terrorist financing on the platform.
Compliance officers maintain the policy by applying a risk-based approach while monitoring the transactional activity on the exchange.
All transactions on the platform are also automatically analyzed for suspicious patterns by the AML system. If a transaction or user’s activity, in general, raises suspicion, the case is then investigated by an appropriately trained Compliance officer. Compliance officers have the right to suspend transactions for the time of the investigation.
The company does not provide its services to natural persons or legal entities that are under sanctions, including, but not limited to the sanction lists of the UN, EU, OFAC.