Being guided by this AML/KYC Policy, TRUSTDEAL LTD in the course of its business activity undertakes to comply with all international laws and requirements related to combating money laundering and terrorism financing. AML/KYC Policy is designed to prevent and reduce potential risks and will prevent TRUSTDEAL LTD from being involved in illegal activities of any kind.
AML/KYC Policy of TRUSTDEAL LTD is based on risk analysis and is aimed at solving specific problems, including:
- Collection, verification and storage of data identifying the User within the framework of “Know Your Customer” (KYC) policy.
- Identification and combating legalization of illegally obtained proceeds and financing of terrorism.
- Enhancing the User's confidence in the financial system.
For these purposes TRUSTDEAL LTD developed its internal policy and a set of measures aimed at its implementation, including:
1. Identity verification.
When registering on the website of TRUSTDEAL LTD Service, the User undertakes the following:
- To comply with all applicable laws on combating the legalization of illegally obtained proceeds, including, but not limited to, AML/CTF Policy, and follow all associated rules and regulations.
- To agree that they have no information or suspicions regarding the fact that the funds used to replenish the account in the past, present or future are obtained from an illegal source or somehow related to legalization of proceeds obtained illegally or as a result of unlawful activities prohibited by the current legislation or guidelines of any international organization.
- To agree that they have no information or suspicions regarding the fact that the profits received from transactions carried out through the Service will be used to finance illegal activities.
- To agree to immediately provide any information that TRUSTDEAL LTD considers necessary to request for the purposes of compliance with applicable laws and regulatory requirements with respect to combating legalization of illegally obtained proceeds.
In accordance with the Policy, TRUSTDEAL LTD will conduct primary and current identity checks of company Users based on the level of potential risk associated with every User.
TRUSTDEAL LTD will require every Company client to provide minimum information confirming their identity and will store this information indicating the methods and results of the check.
TRUSTDEAL LTD will inform the User about any inconsistencies found or suspicions that may arise during their identification. The minimum set of identification data includes:
- Client's full name.
- Client's date of birth.
- Client's citizenship.
- Client's residential address.
- Client's business occupation, financial soundness.
To confirm and verify the authenticity of the above data, TRUSTDEAL LTD is entitled to request the following data from the client:
- Valid passport.
- National identity card (driver's license, etc.).
- A document confirming the client's address of permanent residence at a given time (confirmation of payment for utilities, bank statement, etc.).
TRUSTDEAL LTD hereby declares that transactions can be conducted through the Service solely for the purposes of exchange to eliminate risks associated with combating legalization of illegally obtained proceeds and terrorism.
2. Control of transactions conducted by the User
TRUSTDEAL LTD carries out daily control for the purposes of risk assessment, identification of unreliable Users and suspicious transactions.
To this end, the Company performs a set of activities that includes data collection to identify suspicious and wrongful acts on the part of Users, identify “suspicious” transactions based on the Company's policy, maintenance of lists and records, initiation and carrying out of investigations, compilation of reports on the works done.
The purpose of this set of activities is to find out whether the transactions performed are suspicious or not.
In the event TRUSTDEAL LTD has sufficient reasons to believe that the Service is used by the User in violation of the legislation and/or internal Policy on combating legalization of illegally obtained money and terrorism and/or for purposes other than those ones defined above, the Company reserves the right to suspend transactions carrying out and deny access to the User's Personal Account until the circumstances are clarified.
Based on the above provisions, TRUSTDEAL LTD is entitled to conduct an internal check of suspicious transactions, which may last up to 90 (ninety) days.
The grounds for checking and requesting data can be buying, selling, and exchanging of large amounts of financial instruments, transactions carried out frequently or at a certain period of time, transactions for the same amounts, attempts to use account details belonging to third parties for buying, selling, and exchanging financial instruments.
TRUSTDEAL LTD is also entitled to notify relevant government authorities and other interested agencies about detected suspicious and/or illegal transactions carried out through the Service.
3. AML Officer
AML officer is an authorized officer of the Company whose responsibility is to ensure the effective implementation of AML/KYC Policy.
AML Officer is responsible for the control of all aspects of TRUSTDEAL LTD activities related to combating money laundering and financing of terrorism, including:
- Collection of user identification information.
- Identification of suspicious transactions.
- Establishing and updating internal policies and procedures for the completion, review, submission and storage of all reports and records required by applicable laws and regulations.
- Monitoring of transactions and investigating any and all significant deviations from normal activities.
- Introduction of a records management system for proper storage and retrieval of documents, files, forms and logs.
- Regular risk assessment.
- Providing law enforcement agencies with information in accordance with the requirements of applicable laws and regulations.
AML Officer is entitled to interact with law enforcement agencies involved in anti-money laundering, financing of terrorism and other illegal activities.
4. Risk mitigation
In accordance with international requirements TRUSTDEAL LTD adopted a risk-based approach in its AML/KYC Policy.
By applying this approach, the Company ensures that its measures aimed at prevention and combating money laundering and financing of terrorism are proportionate to anticipated risks, contribute to their prompt identification and mitigation, but require daily special attention and continuous effective development. This approach will allow the Company to set priorities correctly, distribute its resources in the most efficient way, and contribute to the struggle of the International Community against this evil.