AML-KYC

Anti Money Laundering (AML) Policy

Financial institutions and closely related entities (such as e.g. cryptocurrency exchanges) experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

Swapiner pays thorough attention to any activities that may be considered as money laundering or terrorist financing. Swapiner AML policy is designed to prevent money laundering by complying with Seychelles AML legislation along with Global obligations including the need to have adequate systems and controls in place to mitigate the risk of being used to facilitate the financial crime.

To minimize and mitigate the risk of money laundering and terrorist financing, Swapiner implemented effective internal measures and procedures:

1. Establishment of the Identity

Before any customer can access and benefit of Swapiner services, identity of such customer has to be established. For Swapiner to be able to establish the identity of its customer, Swapiner must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of Swapiner pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. Swapiner retains a right to re-establish the identity of the customer in cases where Swapiner Limited sees it fit and in relation to that, request additional data/documents/information or renew previously submitted.

Customer’s identification information will be collected, stored, shared and protected strictly in accordance with Swapiner Privacy Policy and related regulations.

Establishment of the Identity, PEP and Sanctions check

1a. KYC Check;

1b. PEP Screening;

1c. OFAC and Sanction Screening;

1a. KYC Check

KYC refers to a process that banks and other financial institutions use to gather identifying data and contact information from current and potential customers. Its purpose is to prevent fraud, money laundering, and other illicit activity, as well as the misuse of financial accounts. Please follow KYC page for more details.

1b. PEP Screening

Politically Exposed Person (PEP) have to be seen as high risk by financial institutions due to their potential to engage in bribery and corruption. Financial institutions are not forbidden to open accounts for PEPs, but AML regulators have financial institutions necessary to detect PEPs due to high risks. Swapiner protect Politically Exposed Person using a powerful PEP Screening VisionIQ Data as a Service tool https://www.kyc2020.com work with real-time data fast and securely through API and manually.

1c. OFAC and Sanction Screening

Detect Risk Threats; Swapiner protect business threats using a powerful Sanction Screening VisionIQ Data as a Service tool https://www.kyc2020.com work with real-time data fast and securely through API and manually. Sanction screening generally find criminals who have committed the following crimes like Terrorism, Drug trafficking, Human Rights Violations, Weapon Proliferation, Terrorist Financing, Money Laundering. VisionIQ data screening inluding this list:

Sanction & Terrorist Lists

Sanction & Terrorist ListsAll 37 FATF member countries & 180+ observing members

Criminal & Enforcement Lists

Criminal lists such as RCMP, FBI, No-Fly, Sex Offenders, & more

Adverse Media Lists

Relevant global news sources are screened for financial crime

PEP Lists

Over 198 countries at the Federal level plus RCAs

Regulatory Authority Lists

All as mandated by FATF including HIO

High Risk Business Lists

Cannabis Related Businesses, MSBs, Casinos, & more

2. Assessment of Risk

To mitigate and minimize the risks, Swapiner has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which Swapiner Limited is exposed, and take the appropriate mitigation measures in accordance with the level of risk. Risk based approach also allows to pay most of the attention to the higher risk and allocate most of the resources for mitigation of such risks.

Assessment of risk:

2a. Blockchain transaction check

2b. Monitoring of the customer’s activities, Incoming/outgoing transfer; and

2c. Rejection of restricted countries; blacklisted, Greylisted and High-risk countries;

2d. Reporting of suspicious activities to respective authorities if necessary or asked hereby;

2a. Blockchain Transaction check

Know Your Transaction (KYT) Screening Crypto wallets and transactions to identify the source of funds and provide detailed report through a Crypto Screening tool, the tools work with real-time data fast and securely via API and manually. Determine the risk score of any wallet to avoid problems with regulatory authorities and to protect Swapiner from illicit funds. The tool generally work for Checking wallets for illicit funds and Protecting users and businesses from unwitting participation in financial crimes. We are usiness https://amlbot.com for Blockchain transaction check..

2b. Monitoring of the customer’s activities, Incoming/outgoing transfer

To get to know its customers, Swapiner performs ongoing and retrospective monitoring. Monitoring performed by Swapiner intends not to only to get to know the customer, but also to notice unconformities taking into comparison information submitted to Swapiner by the customer or obtained by Swapiner during establishment of the identity and such customer’s actual activities using Swapiner services and to catch any attempts of fraudulent, illegal or unlawful activity.

Swapiner uses both manual and automated solutions to track its customers’ transactions. Swapiner may use other measures on case by case basis.

Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures taken to ensure no money laundering or terrorist financing activity is performed. Swapiner is entitled to request additional information/data/documents in relation to any transaction and the customer must follow the such request.

All Outgoing Banking Transfers user must be KYC verified and additionally require the following information for verification and security reasons:

• Purpose of payment

• Supporting documentation (source of fund)

• Information on the receiving party

• Confirmation that the client did indeed request the transfer submitted.

• If client documentation supplied being verified and confirmed legitimate, the Outgoing Wire Transfer can be executed.

Detecting a Suspicious Transaction is based on the following transaction situations:

• Out of the ordinary transaction based on the clients’ transaction history

• If the beneficiary or originating account name is found to be associated to any form of illegal financing or financial fraud during security checks

• If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer

• If the transfer is destined for a black listed or sanctions country

• If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame If it is felt that a transaction is deemed suspicious, it is required that the processing of the transaction be discontinued and reported.

Outgoing Banking Transfers should be declined in any one of the following circumstances:

• Insufficient documentation

• Beneficiary account held in a black listed or sanctions country

• The beneficiary bank account name must be same as Swapiner account name, for any mismatches Declined the transactions

All Incoming Banking Transfers user must be KYC verified and additionally require the following information for verification and security reasons:

• Source of funds

• Supporting documentation (clearly confirming the purpose of payment and the remitting party)

• Information on the remitting party

A suspicion may be based upon a transaction or activity, which is inconsistent with a customer’s known legitimate business, activities or lifestyle or with the normal business for that type of product/service.

Detecting a Suspicious Transaction can be based on the following transaction situations:

• Out of the ordinary transaction based on the Clients transaction history

• If the remitting account name is found to be associated to any form of illegal financing or financial fraudulent activity

• If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer

• If the transfer is destined for a black listed or sanctions country

• If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame.

Incoming Banking Transfers should be declined in any one of the following circumstances:

• Insufficient documentation

• Remitting account name is a listed individual/corporate

• Remitting account held in a Black Listed or sanctions Country

• Unable to prove source of funds

• Value exceeds Individuals means and resources

2c. Swapiner do not process any Blacklisted and Greylisted countries banking transfer which describe bellows:

The Financial Action Task Force (FATF) blacklist (sometimes referred to as the OECD blacklist) is a list of countries that the intragovernmental organization considers non-cooperative in the global effort to combat money laundering and the financing of terrorism. By issuing the list, the FATF hopes to encourage countries to improve their regulatory regimes and establish a global set of AML/CFT standards and norms.

The current FATF blacklist countries:

1) North Korea

2) Iran

3) Russia

The current FATF Greylists countries:

Albania, The Bahamas, Barbados, Cambodia, Iceland, Jamaica, Mauritius, Mongolia, Myanmar, Nicaragua, Panama, Syria, Yemen and Zimbabwe.

Swapiner do not process banking transfer to any High-risk Third countries and Non-cooperative Jurisdictions

High-risk Third countries: Afghanistan, The Bahamas, Barbados, Cambodia, Democratic People's Republic of Korea (DPRK), Iran, Iraq, Jamaica, Mauritius, Myanmar, Nicaragua, Panama, Syria, Trinidad and Tobago, Vanuatu, Yemen, Zimbabwe.

Non-cooperative jurisdictions for Tax purposes: The Economic and Financial Affairs Council of the EU (ECOFIN) adopted a revised EU list of non-cooperative jurisdictions for tax purposes (the EU blacklist). Following this latest revision, the EU blacklist includes the following jurisdictions: American Samoa, Anguilla, Barbados, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands, Vanuatu.

Swapiner also not process banking transfer where Bitcoin is Banned or illegal!

Countries where Bitcoin is banned or illegal: Algeria, Bolivia, Dominican Republic, Ghana, The Republic of Macedonia, Quatar, Vanuatu.

3d. Reporting to the Authorities

Following its AML Policy and the applicable legal acts, Swapiner , when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. Swapiner will not disclose any information about such report to have been made and will not address any questions in relation to that.

Compliance officer

Swapiner has the assigned Compliance officer who is responsible for implementation of Swapiner AML policy, including but not limited to, of the above listed activities.

Data Storage

The storage of customer due diligence (“CDD”), transaction documents, wire transfer records, internal and external suspicion reports and compliance monitoring reports are retained and stored electronically via an online storage facility.

Each client has a folder created under their username on the opening of their Swapiner account. All KYC documentation and security check reports are saved in a sub folder for compliance documentation. Documentation in regards to payment transactions is stored in a further sub folder for payments & reports. Documentation can be retrieved from the online storage facility as and when required by the Swapiner administrators and authorized users, via login details requiring a password for access to the data.

Know Your Customer (KYC)

Registration / Verifying Identity

1) If you wish to place an Order, and provided you meet the Eligibility Criteria, you will first be required to register as a User. You can open a Standard Account by providing your email address.

2) If you require exchange with full limit, to comply with our legal/Internal Compliance obligations, we will ask you to follow a two-step process to open an Account:

a) submission of the Individual or Corporate Application which can be found on the Platform; and

b)signing of the Certified Board Resolution document in the case of a Corporate Application.

3) 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:

a) For an individual User: A high-resolution scanned copy or photo of pages of a passport or any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of Issue and User's signature. Swapiner system may request to upload a high resolution selfie with one hand ID + a Note (for Swapiner.com) to ensure user uploaded document himself and provided document only for Swapiner.com

b) For a corporate User: A high-resolution copy of documents showing the existence of the entity, such as Certificate of Incorporation, and, where applicable, Certificate of Change of Name, Certificate of Good Standing, Articles of incorporation, a government issued business license (if applicable), etc.

c) 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.

The User is obliged to collaborate with regard to the KYC check and to provide any information and document deemed necessary by the Company.

4. The Company may reject any User in its sole discretion after the without being obliged to disclose any reason for the rejection.

5. 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 KYC check within 15 (ten) days which are not public holidays in Seychelles of the Company's request, Swapiner may Reject/Restrict the User.

Additionally, the Issuer has the right to partially or fully withhold the received amounts for any costs or damages incurred by the Issuer. All kind of remittance fees either for fiat currency or for cryptocurrencies shall be borne by the User.