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Anti-money laundering policy Both international and local regulations and legislation require Ecash.Expert to implement effective internal procedures to prevent any illegal activity and to take all necessary measures to do so. Ecash.Expert adheres to the practice in the field of combating legalization (laundering) of the proceeds of crime and the financing of terrorism (AML - Anti Money Laundering), as well as the policy of "Know your client" (KYC). AML / KYC policy covers the following issues: - Verification procedures; - Transaction monitoring; - Risk assessment. 1. Verification procedures 1.1. Proof of identity Ecash.Expert verification procedure requires the User to provide authentic documents (for example, international passport, account statement, utility bill, etc.) to the service administration. For such purposes Ecash.Expert reserves the right to collect user identification information within the framework of anti-money laundering policy and «Know your client» policy. Also, Ecash.Expert reserves the right to additionally check certain Accounts that have aroused suspicion. The verification process includes providing documents confirming the User’s identity. For individuals: 1) To verify your identity, the User must provide one of the following documents: - a civil passport; - international passport; - ID card. 2) To confirm the address, the User must provide one of the following documents: - bank statement, where the address of your actual residence is clearly visible; - utility bill, where you can clearly see the address of your actual residence; - tax documents that clearly show the address of your actual residence; - a document confirming the address of your actual residence issued by the local authorities, where the address of your actual residence is clearly visible. For corporate clients: 1) To verify your identity, the User must provide one of the following documents: - the civil passport of the director; - international passport of the director; - Director’s ID; 2) To confirm the address, the User must provide one of the following documents: - bank statement, where the address of your actual residence is clearly visible; - utility bill, where you can clearly see the address of your actual residence; - tax documents that clearly show the address of your actual residence; - a document confirming the address of your actual residence, issued by the local authorities, where you can clearly see the address of your actual residence. 3) To confirm that the User is the authorized representative of the organization, he must provide all the following documents: - a document confirming the legal address of the company; - the document on registration of the legal entity; - Order appointing a director; - scanned copy or photo of the letter about the decision to work with Ecash.Expert 4) Information on the ultimate beneficiary: Civil passport of the final beneficiary; - international passport of the final beneficiary; - ID of the final beneficiary; — document confirming the address of the final beneficiary. The final beneficiary, according to the Cyprus legislation, means the natural person who owns or controls the Account of the User and/or the natural person on whose behalf transactions are made. 1.2. Bank card verification Users who wish to exchange a bank card must first verify it. You can find detailed verification instructions here. 2. Monitoring transactions Users are checked not only by verifying their identity but also by analyzing their transactions. Therefore, Ecash.Expert relies on data analysis as a tool for risk assessment and detection of suspicious User activity. Ecash.Expert carries out data collection, filtering, record keeping, investigation management and reporting. Regarding the AML / KYC policy, Ecash.Expert can track all transactions and reserves the right to: - to request from the User any additional information and documents in case of suspicious transactions; - suspend or block an Account if Ecash.Expert has reasonable suspicion that this User is engaged in illegal activities. The above list is not exhaustive, and transactions will be tracked on a daily basis to see whether transactions should be treated as suspicious. 3. Risk assessment Ecash.Expert, in accordance with international requirements, checks transactions for risk with AML-services. Therefore, a transaction may be rejected if the total risk exceeds 50%. The Service may also refuse to provide services to the User if the risk exceeds 1.5% in the following categories: - Dark Service - coins related to child abuse, terrorist financing or drug trafficking; - Dark Market - coins that were used for purchases in the dark net; - Scam - coins that were obtained by deceiving their customers; - Mixer - coins were passed through the mixer to make their tracking difficult or impossible. Often used for money laundering; - Illegal Service - coins related to illegal activities; - Ransom - coins obtained through extortion or blackmail; - Exchange Fraudulent - coins from exchanges related to fraud, illegal activities, or the funds of which were seized by the government; - Stolen - stolen coins; - Gambling - coins associated with online casinos without a license. In the event that the transaction is highly risky, the User must pass a KYC verification to confirm the identity. 4. Conduct of exchange Ecash.Expert warns users against attempts to use Ecash.Expert to legalize money obtained through criminal activity, financing terrorism, fraud of any kind, and using the service to purchase prohibited goods and services. In order to prevent illegal operations, the Service sets certain requirements for all Applications created by the User: 4.1. The sender and recipient of the Request Payment must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited. 4.2. The contact data entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be authentic and relevant. Upon request of the User, personal data may be removed from the Service’s database within 3 years from the date of the last implemented User’s Request. 4.3. In case of reasonable suspicion by the administration of the Service that the user tries to use the services of the Service for money laundering or for the purpose of conducting any other illegal operations, the administration has the right: - suspend execution of user’s exchange operation; - request identification documents from the user; - request other information regarding payments; 4.4. All information provided by the customer may be transmitted to the supervisory authorities in the following cases: At the request of law enforcement agencies; By decision of courts of different instances; - at the request of Payment System administrations. Personal data includes: - surname, first name, patronymic; - e-mail address; - Country of residence/citizenship; - Details of purses used; - mobile phone number; - data of an identity document; - location address 4.5. Processing of personal data means recording, systematization, stockpiling, storage, clarification (updating, modification), extraction, use, transmission (dissemination, provision, access), including cross-border, anonymization, blocking, deletion, destruction of personal data, which do not fall under special categories, processing of which requires the written consent of the User. 4.6. Processing of personal data is carried out in order to fulfill the obligations of the Parties under the Agreement, registration of the User on the Site of the Service, provision of technical support to the User, registration of Applications, rendering Services, consideration of appeals and claims, sending information and other messages to the User’s e-mail address. 4.7. The basis giving the Service the right to process the User’s data is the User’s consent. The consent is given in the form of clear active actions of the User, namely one or a set of these actions: registration of the User on the Site of the Service and independent provision by the User of the necessary data in the process of such registration, filling in the electronic form via the Service’s Internet site for the purpose of submitting the Application, making payment for the Application and other active actions using the Service. Ecash.Expert reserves the right to: 1) Require the User to provide additional information revealing the origin of digital assets and/or proof that those assets were not the proceeds of crime; 2) block the account and any transactions connected with the User, transfer to the controlling financial activity and/or law enforcement bodies at the place of registration of the Service and, if necessary, at the address of registration of the Client all information and documents available on the incident; 3) demand from the User documents confirming identity, video verification, registration address, solvency; 4) to return digital assets only to the details from which the transfer was made, after full verification by the security service of the Service, if it was possible to verify the legal origin of the Client’s funds; 5) Refuse to withdraw funds to the account of third parties without explanation; 6) Hold the User’s funds until the incident is fully investigated; 7) Monitor the entire transaction chain to identify suspicious transactions; 8) Refuse to provide the Service to the User if the Service has reasonable suspicions in the legality of the origin of digital assets or in the case it is impossible to trace the entire chain of movement of assets from the moment of their appearance, and to retain funds on the special accounts of the Service.