Know Your Customer (KYC) and Anti-Money Laundering
(AML) Policy and Procedures
This is the policy that guides shopinna in prohibiting and preventing money laundering and any activity that
facilitates money laundering or the funding of terrorist or criminal activities
by complying with all applicable legal requirements of Gibraltar.
Money laundering is generally
defined as engaging in acts designed to conceal or disguise the true origins of
criminally derived proceeds so that the proceeds appear to have derived from
legitimate origins or constitute legitimate assets. Terrorist financing may not
involve proceeds of criminal conduct but is rather an attempt to conceal either
the origin of the funds or their intended use.
Although the motivation differs
between traditional money launderers and terrorist financiers, the actual
methods used to fund terrorist operations can be the same as or similar to
methods used by other criminals to launder funds. Funding for terrorist attacks
does not always require large sums of money and the associated transactions may
not be complex.
Our AML policies, procedures and
internal controls are designed to ensure compliance with all applicable
regulations, rules and laws and will be reviewed and updated on a regular basis
to ensure appropriate policies, procedures and internal controls are in place
to account for both changes in regulations and changes in our business.
The Company operates in compliance with
‘anti-money laundering (“AML”) and ‘know your customer’ (“KYC”) rules and
regulations in the jurisdictions it operates in or sells products or services
to and has developed the given KYC and AML Policy to protect itself from
involvement in money laundering or suspicious activity as follows:
- The Company is performing an
enterprise-wide risk assessment to determine the risk profile of the Company.
- The Company has established KYC and AML
policies and procedures that have been reviewed and approved by the Company’s
Board of Directors (the “Board”).
- The Company is implementing internal
controls throughout its operations designed to reduce risks of money
laundering, including designating a person responsible for AML compliance. The
Company performs know your customer (“KYC”) procedures on all token sale
POLICIES AND PROCEDURES
1.Purchaser Identification (Know Your Customer)
The Company collects identifying information
on each vendor and purchaser in its token sale. The Company shall collect the following
information about each purchaser:
and back) of ID Data collected from ID:
Date of birth,
photograph (with ID in Hand) A Description of Source of Funds PEP checks with
filters like Worldcheck
business registration number or tax identification number
Copy of a recent trade registers extract or
Representative, compare Individual of KYC process
Even after KYC
approval the Company can do additional checks and ask for further documents.
shall not accept purchasers (individuals or entities) who are not at least
eighteen (18) years of age or purchasers from the following jurisdictions (the
The Company shall screen each prospective purchaser in
its token sale for matches in the following categories:
- Global Sanctions List - Screening prospective
purchasers against OFAC Sanctions.
- PEPs - Screening prospective purchasers for
identification as a "politically exposed person". A PEP is a term
describing someone who has been entrusted with a prominent public function. A
PEP generally presents a higher risk for potential involvement in bribery and
corruption by virtue of their position and the influence that they could hold.
- Adverse Media
- Screening prospective purchasers against adverse media involves looking for
any negative mentions of them in traditional news media and publicly available
information more broadly. Any prospective purchaser that has a match on any of
the above categories shall be flagged and blocked pending review by the Company
and its counsel of the red flag. The prospective purchaser will receive an
email letting them know of that it is under review and a follow-up email
letting the prospective purchaser of the disposition of the review.
4.Dispositions of AML Flags
Sanctions List - If the flag is a match on the Global Sanctions List, the
Company shall deny the purchaser and let them know of the disposition of the
receiving any additional verification information, the Company shall provide
the prospective purchaser with notice of disposition.
Media - If the flag is a match on Adverse Media, the Company’s counsel shall
review the adverse media and make a determination on whether to allow the
Appointment of an AML Compliance Person - Designation and Duties The Company is
in the process of designating a compliance person to be its Anti-Money
Laundering Program Compliance Person (AML Compliance Person), with full
responsibility for the firm’s AML program. The duties of the AML Compliance
Person will include monitoring the firm’s compliance with AML obligations,
overseeing communication and training for employees.