DOCUMENTS ANY.MONEY

The objective of the Anti-Money Laundering and Know-Your-Customer Policy ("AML/KYC Policy") is to prevent money laundering and terrorist financing activity on the Service by meeting the international and domestic legislation requirements and implementation of identification procedure of users.

According to the AML/KYC Policy, "Any.Money", "Company", "we", "us" or "our" refers to the company DBR SECURITY LTD , including, without limitations, its owners, directors, investors, employees and other related persons. Depending upon the context, "Any.Money" may also refer to the services, products, website, content or other materials provided by Any.Money.

The AML/KYC Policy is an integral part of the Terms of Use. When you accepting the Terms of Use you automatically agree with the AML/KYC Policy.

Capitalized terms not otherwise defined in this AML/KYC Policy have the meaning as they are defined in the Terms of Use.

Definitions

Capitalised terms used in this Anti-Fraud Policy have the following meaning:

Prohibited Conduct means any illicit conduct that includes fraud, corruption, money laundering, collusion, terrorist financing and any other criminal conduct.

Fraud means use of deception with the intention of pursuing personal interests and causing loss to the proper interests of Users and/or Any.Money.

Corruption means offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the action of another party.

Money laundering means a financial transaction scheme that aims to conceal the identity, source, and destination of illicitly-obtained money.

Collusion means arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.

Terrorist financing means provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences on combating terrorism.

Criminal conduct means an offence in any part of the world or would constitute an offence in any part of the world if it occurred there.

Capitalised terms not defined in this Anti-Fraud Policy have the meaning as they defined in the Terms of Use.


1. General Provisions

1.1. The company shall comply with the requirements contained in the local and internaional Acts on Prevention of Money Laundering and Terrorism Financing, as well as the requirements of other laws and regulations to the extent in which they relate to the Company's operations.

1.2. The company develops this AML/KYC Policy, may introduce amendments and additions to it at its own discretion, and will oversee compliance with its provisions and requirements.

1.3. The current version of the Policy is always available on the website at: https://any.money/en/legal/aml-kyc-policy/

2. Merchant Services Officer

2.1. To oversee and implement the procedures reflected in the Policy, the Company appoints a Merchant Services Officer.

2.2. The Merchant Services Officer is responsible for the collection, analysis, and investigation of information on any suspicious activities and the training of the company's employees pertaining to the relevant procedures; the Merchant Services Officer shall determine the procedures and rules for carrying out Customers' identification, reviewing and monitoring unusual transactions

3. Identification Policy.

3.1. For the purposes of Customers' identification, the Company requests the following documents:

• Articles of Incorporation;
  
• registration certificate (certificate of incorporation);
  
• company's shareholders charter;
  
• document confirming the powers and authority of the person authorized to act on the company's behalf without a power of attorney, etc.;
  
• proof of identity (passport, driver's license, national identity card);
  
• proof of address (bank statement, utility bill);
  
• utility bill;
  
• goodstanding letter.
  
  

3.2. KYC procedure applies to Users suspected in committing illegal transactions. We may request you the following documents to make your identification:
Personal identification documents:

• National and/or international passport;
  
• National ID card.
  

Proof of address:

• Copy of a utility bill;
• Telephone bill, electricity bill;
  
• Bank statement.
  

Other documents such as driver license etc.

4. 'Know Your Customer' Verification Procedures

4.1. The Company conducts the Know Your Customer (KYC) verification procedures to avoid the risk of being held liable and to protect itself from a Customer's attempting to use the Company for carrying out illegal activities.

4.2. As part of the KYC procedures, the Company evaluates Customers' transactions, as well as collects and stores information on the essential facts pertaining to Customers, potential Customers, and their transactions.

4.3. After carrying out the identification procedures pertaining to a Customer, the Company stores the information obtained in this Customer's file. The Company is under obligation to carry out the identification procedures pertaining to a Customer once.

4.4. The company is committed to protecting Customers' rights and the confidentiality of their personal data. The Company collects personal information from Customers only to the extent necessary to ensure the Company's properly providing services to Customers. Such personal information about Customers and former Customers may be disclosed to third parties only in a limited number of circumstances, in accordance with the applicable laws and agreements between the Company and the Customer.

4.5. The company shall carefully maintain Customers' files, including statements, transaction reports, receipts, notes, internal correspondence, and any other documents related to the customer in electronic format for as long as may be required by the underwriting teams at the relevant acquiring banks / processors that the Customer makes use of.

4.6 The Company has the right to suspend the Account that is involved in suspicious activity and request the owner of such Account to pass the KYC procedure.

5. Identification and Detection of Suspicious Activities

5.1. Any financial transaction that may be related to money laundering activities shall be considered to be suspicious activities.

5.2. Grounds for determining that a specific transaction is suspicious may be personal observations and experience of the Company's employees, as well as information received or identified.

5.3. The Merchant Services Officer shall continuously monitor and update the systems used by the Company to detect suspicious activities.

5.4. In accordance with the applicable laws and the requirements of international organizations, the Company may, where appropriate and without the obligation of obtaining the Customer's approval or notifying the Customer, notify regulating and/or law enforcement agencies of any suspicious transactions.

5.5. The Company shall periodically refer to and consult the lists published by the local authorities and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to the OFAC sanctions, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company's Customer or potential Customer, and/or such Customer's country of jurisdiction is included in the above lists.

5.6. The Company shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions' compatibility with the Company's knowledge of its Customers, their business and, when necessary, their source of funds.

6. Amendments and modifications

6.1. This KYC Policy may be modified or amended at any time, at the sole discretion of Any.Money. You acknowledge and agree that it is your own responsibility to review the KYC Policy periodically and become aware of amendments and modifications.

6.2. If you do not wish to accept the modified and/or amended KYC Policy, you should not continue to use the Service. Your continued use of the Site and/or the Service following the posting of changes to the KYC Policy will be deemed as your acceptance of those changes.

7. Third Parties

7.1. To perform some of its business functions, the Company may use third-party service providers. The company shall make an effort to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any initiated investigations and filed lawsuits against any such third-party service providers. The company shall also determine whether a third-party provider has obtained all the necessary licenses, permits, and approvals before establishing a business relationship with such third-party service provider.

7.2. With respect to its own staff, the Company shall carefully review all candidates for employment and determine whether the activities of a new employee fall in the category that is susceptible to money laundering activities. In addition, the Company has prepared and implements a number of personnel training programs on customer identification procedures and prevention of money laundering activities.

8. User's Statement/strong

8.1. Using our service you warrant and guarantee that you have no intention to commit any of prohibited conduct acts described herein; furthermore, you consent to any checks due to investigation under the Anti-Fraud Policy and you agree to cooperate fully and promptly with the Anti-Fraud commissioner within such investigation

9. Compliance Statement

9.1. The Corporate Customer (the Corporate Customer's authorized employee) certifies that they have read and understood this Policy, and that they (or their company) shall operate in full compliance with the requirements and standards outlined in the Policy and comply with all applicable laws and other regulations and requirements governing its activities as a Corporate Customer.

9.2. The Corporate Customer (the Corporate Customer's authorized employee) acknowledges that they are responsible for their actions in accordance with the effective laws in the field discussed in this Policy and shall bear responsibility pertaining to failure to comply with such laws.