AML/KYC Policy
1CUSTOMER IDENTIFICATION PROCEDURE
1.1 IdentificationIf a transaction is flagged as suspicious by our risk scoring system, it will be put on hold, and we may collect the following information from the customer or any applicable person, entity, or organization:
- Full name;
- Date of birth (for individuals);
- Residential and business address (for individuals) or principal place of business, local office, or other physical location (for entities other than individuals);
- For individuals: a valid government-issued identification document, such as a driver’s license or passport, evidencing nationality or residence and including a photograph or similar safeguard;
- For entities other than individuals: documentation proving the entity’s existence, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument.
1.2 Verifying InformationBased on the assessed risk and to the extent that it is reasonable and practicable, we will proceed with verification once we have gathered all the necessary information to accurately establish the identity of our customers. This process will involve using risk-based procedures to verify and document the accuracy of the information we collect.
We have engaged a third-party service provider, Sum & Substance Ltd, which fully complies with our Privacy Policy regarding the handling of personal information. Sum & Substance Ltd will review the information we collect to determine:
- Whether the information is sufficient to reasonably believe that we know the true identity of the customer (e.g., by checking for logical consistency or discrepancies).
- Whether the documents provided by the customer are valid and do not appear on the Specially Designated Nationals and Blocked Persons List, or any other list of sanctioned individuals.
We will complete the verification process within a reasonable timeframe, depending on the nature of the account and the risk level of the transactions. We reserve the right to refuse to complete a transaction until the information has been verified. In some cases, if more time is needed, we may suspend transactions pending verification if there is suspicion regarding the information provided.
1.3 Customers Who Provide Misleading InformationAfter submitting the information, the customer must ensure that it is accurate, complete, and up-to-date. If we have any reason to believe that the information provided by the customer is incorrect, false, outdated, or incomplete, we reserve the right to send a notice requesting correction. Depending on the situation, we may also blacklist the customer's account and terminate all or part of the services we provide to the customer.
1.4 Notice of AML/KYC ChecksWe inform customers that their transactions may be subject to Anti-Money Laundering (AML) and Know Your Customer (KYC) checks. This information is fully outlined in our Terms of Use, and it is the customer's responsibility to review these Terms before initiating any transactions. If we are unable to reasonably confirm the true identity of a customer, we will request additional information.
2MONITORING OF TRANSACTIONS
Ongoing monitoring is a crucial component of effective KYC procedures. We maintain an understanding of the customer's normal and expected activity, allowing us to identify transactions that deviate from their usual pattern. This helps us detect and respond to any suspicious activities.
3AML COMPLIANCE OFFICER
The AML Compliance Officer, appointed by Explace, is responsible for implementing and effectively monitoring the application and enforcement of the AML/KYC policy outlined in this document. This officer oversees all aspects of Explace’s anti-money laundering and counter-terrorist financing efforts. Any suspicious behavior or activities should be reported to the AML Compliance Officer. Communication regarding this policy can be made via [email protected].
4RISK MANAGEMENT
We have established appropriate procedures to ensure the effective implementation of KYC guidelines. These procedures include proper management oversight, systems and controls, segregation of duties, training, and other related measures. The Explace security team will periodically conduct quality checks and file audits to ensure compliance with KYC policies and procedures. Additionally, the security team will update senior management on any issues that arise during the customer acquisition process.
5COLLABORATION WITH LAW ENFORCEMENT
When necessary, we may request accurate and necessary information about the sender and recipient during virtual asset transfers. This information will be provided to the relevant authorities upon official request.