1. This Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) of JUSTAPP OU, a company registered under the laws of the Estonia with registry Code 14455112, at Harj maakond, Tallinn, Kesklinna linnaosa, Narva mnt 7-634, 10117 (“We”, “Us”, or the “Company”), reflects main provisions of the Company`s compliance policies designated to prevent and mitigate possible risks of the Company being involved in any kind of illegal activity.
2. Both international and local regulations require the Company to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
3. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, the Company establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
4. The Company identity verification procedure requires the User to provide the Company with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes the Company reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
5. The Company will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and the Company reserves the right to investigate certain Users who have been determined to be risky or suspicious.
6. The Company reserves the right to verify User’s identity in an on-going basis, especially when their activity seemed to be suspicious (unusual for the particular User). In addition, the Company reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
8. Once the User’s identity has been verified, the Company is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity
9. The Compliance Officer is the person, duly authorized by the Company, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer's responsibility to supervise all aspects of the Company`s anti-money laundering and counter-terrorist financing, including but not limited to;
10. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
11. The Company enforces a strict anti-money laundering policy with zero tolerance for money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.
12. All the Company`s affiliates are obligated to comply with this anti-money laundering policy and internal AML Manuals and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
13. The Company ensures complete compliance with laws pertaining to anti money laundering through its related policy.
14. The Company implements a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operation throughout the Company`s Platform.
15. All Company`s Users acknowledge, undertake and agree to the following terms regarding their use of the Platform, opening and maintenance of accounts at Platform and for all financial transactions as Company`s clients:
16. Activities that the Company considers possible indications of money laundering include:
The above list is by no means an exhaustive list. The Company monitors its User and account activity in light of several other red flags and takes appropriate measures to prevent money laundering.
17. The User acknowledges that he/she/it has to complete a KYC check for the Use of the Website, which must be in form and substance satisfactory to the Company. KYC check is carried out after completing of the registration at the website by providing necessary information with regard to identification of the User, beneficial owner and origin of the funds.
18. During the User’s account registration process an individual User provide the following identification information to the Company:
19. During the User’s account registration process corporate Users provide the following identification information to the Company:
20. After receiving the identification information, the Company’s staff should verify this information requesting the appropriate documents. Appropriate documents for verifying the identity of User include, but are not limited to, the following:
21. To verify proof of address of the User the Company requires one of the following to be provided, in the same correct name of the customer: a high-resolution copy of a utility bill (fixed-line phone, water, electricity) issued within the last 3 months; A copy of a tax or rates bill from a local authority; A copy of a bank statement (for a current account, deposit account or credit card account); A copy of a bank reference letter.
22. The User is obliged to collaborate with regard to the AML/ KYC check and to provide any information and document deemed necessary by the Company.
23. The Company may reject any User in its sole discretion after the without being obliged to disclose any reason for the rejection.
24. In case the automatic procedures fail, the Company shall contact the User by email or other means to obtain the information and documents needed. In case the User does not provide the documents in the requested form and any other information requested to satisfy the AML/KYC check within 10 (ten) days which are not public holidays in Estonia of the Company's request, the Company may reject the User and the costs for the AML/KYC check will be at the cost of the User. Additionally, the Company is entitled to partially or fully withhold the received amounts for any costs or damages incurred by the Company. All kind of remittance fees either for fiat currency or for cryptocurrencies shall be borne by the User.