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GENERAL ANTI-MONEY LAUNDERING POLICY 

1. This Anti-Money Laundering Policy (hereinafter – the "AML Policy") of AjuBit OU (hereinafter "AjuBit"), company registered In Estonia, registry number 14564456 at Harju maakond, Kesklinna linnaosa, Roosikrantsi TN 2-637K, Tallinn, 10119 licensed and regulated by the Financial Intelligence Unit (licenses number: FVR000547, FRK000460 reflects main provisions of AjuBit compliance policies designated to prevent and mitigate possible risks of AjuBit being involved in any kind of illegal activity.

2. Both international and local regulations require AjuBit 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. 

Verification Procedures

3. One of the international standards for preventing illegal activity Is customer due diligence ("CDD"). According to CDD, AjuBit establishes its own verification procedures within the standards of anti-money laundering and "Know Your Customer" frameworks. 

4. AjuBit identity verification procedure requires the User to provide AjuBit with reliable, Independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes AjuBit reserves the right to collect User's identification information for the AML/KYC Policy purposes. 

5. AjuBit 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 AjuBit reserves the right to investigate certain Users who have been determined to be risky or suspicious. 

6. AjuBit 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, AjuBit reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past. 

7. User's identification information will be collected, stored, shared and protected strictly in accordance with the AjuBit Privacy Policy and related regulations. 

8. Once the User's identity has been verified, AjuBit is able to remove Itself from potential legal liability in a situation where its Services are used to conduct Illegal activity. 

Compliance Officer 

9. The Compliance Officer Is the person, duly authorized by AjuBit, 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 AjuBit anti-money laundering and counterterrorist financing, including but not limited to: 

a) Collecting Users' Identification information. 

b) Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the FIU, Estonian laws and regulations. 

c) Monitoring transactions and investigating any significant deviations from normal activity. 

d) collaborate with and report to the FIU on events of suspected Money Laundering or Terrorist Financing, and respond to enquiries of the FIU 

e) report to the MB once a year (or more frequently, if necessary) on compliance with the Rules, and on Transactions with a suspicion of Money Laundering or Terrorist Financing 

f) Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. 

g) Updating risk assessment regularly. 

h) Providing law enforcement with information as required under the FIU laws and regulations and applicable entities laws and regulations. 

10. Notification of FIU Before reporting any Transaction connected with suspected Money Laundering or Terrorist Financing to the FIU, the CO will analyse the content of the information received, considering the Client’s current area of activity, payment practice and other known information. 

11. The Compliance Officer Is entitled to Interact with FIU, which are Involved In prevention of money laundering, terrorist financing and other illegal activity. 

Anti-Money Laundering Policy

12. AjuBit 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.

13. All AjuBit 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. 

14. AjuBit ensures complete compliance with laws pertaining to anti money laundering through Its related policy. 

15. AjuBit 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 AjuBit Platform. 


 16.
All AjuBit Users acknowledge, undertake and agree to the following terms regarding their use of AjuBit, opening and maintenance of accounts at AjuBit and for all financial transactions as an AjuBit client: 

a) The User will comply (throughout the time as an AjuBit client) with all relevant statutes pertaining to money laundering and proceeds from criminal activities.

b. AjuBit operates under certain obligations known as "know-your-client" obligations which grant AjuBit the right to implement anti-money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any Illegal activity regardless of the location of such activity.

c) The User agrees to lend full cooperation to AjuBit with respect to anti-money laundering efforts. This involves providing information that AjuBit requests regarding the client's business details, account usage, financial transactions etc. to help AjuBit perform Its duties as dictated by Applicable laws regardless of jurisdiction.

d) AjuBit reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices.

e) AjuBit reserves the right to suspend or terminate any account or freeze the funds in an account If there is reason to believe that the account is being used for activities that are deemed unlawful or fraudulent.

f) AjuBit has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities as per FIU Guidelines. 

 
17. AjuBit has the right to share client Information with: 

a) Investigative agencies or any authorized officers who are comply with applicable law, including anti-money laundering laws and know-your-client obligations 

b) Organizations that help AjuBit provide the services it offers its clients; 

c) Government, law enforcement agencies and courts; 

d) Regulatory bodies and financial Institutions. 


18. Activities that AjuBit considers possible Indications of money laundering Include: 

a) The client showing unusual apprehension or reservations about AjuBit’s anti money laundering policies. 

b) The client's interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the client's business policy. c. The client falling to provide legitimate sources for their funds. 

d) The client providing false information regarding the source of their funds.

e) The client having a history of being the subject of news that is indicative of civil or criminal violations. 

f) The client seems to be acting as a 'front man' for an unrevealed personality or business, and does not satisfactorily respond to requests for Identifying this personality or business.

g) The client not being able to easily describe the nature of his/her industry.

h) The client frequently makes large deposits and demands dealing in cash only.

i) The client maintains multiple accounts and conducts an unusually high number of Inter-account transactions requests.

j) The client's previously usually inactive account starts receiving a surge of wire activity. The above list is by no means an exhaustive list. AjuBit monitors Its client and account activity in light of several other red flags and takes appropriate measures to prevent money laundering. 


19. Fiat USD/EUR withdrawal Restricted country

a) AjuBit do not send/receive Fiat USD/EUR to United States of America. USA client are restricted for Fiat transaction at AjuBit platform!

b) AjuBit also not process Fiat USD/EUR withdrawal to European Commission list of high risk third countries.

Afghanistan

Cape Verde

Gaza Strip

Liberia

Nauru

Seychelles

Algeria

Central African Rep.

Grenada

Libya

Nepal

Sierra Leone

American Samoa

Chad

Guadeloupe

Liechtenstein

Netherlands Antilles

Solomon Islands

Andorra

Comoros

Guam

Lao PDR

New Caledonia

Somalia

Angola

Congo, Dem. Rep.

Guatemala

Macedonia

Nicaragua

Sri Lanka

Anguilla

Congo, Repub. of the

Guernsey

Madagascar

Niger

St Pierre & Miquelon

Antigua & Barbuda

Cook Islands

Guinea

Malawi

Pakistan

Sudan

Aruba

Cote d'Ivoire

Guinea-Bissau

Maldives

Palau

Suriname

Bahrain

Cuba

Guyana

Mali

Papua New Guinea

Swaziland

Benin

Djibouti

Haiti

Marshall Islands

Puerto Rico

Syria

Bermuda

East Timor

Iran

Martinique

Reunion

Togo

Bhutan

Equatorial Guinea

Iraq

Mauritania

Russia

Tonga

Bolivia

Eritrea

Isle of Man

Mauritius

Rwanda

Trinidad & Tobago

Bosnia & Herzegovina

Ethiopia

Israel

Mayotte

Saint Helena

Tunisia

Botswana

Faroe Islands

Jersey

Micronesia, Fed. St.

Saint Lucia

Turks & Caicos Is

British Virgin Island

Fiji

Kiribati

Moldova

ST and Grenadines

Uganda

Brunei

French Guiana

Korea, North

Montserrat

Samoa

Vanuatu

Burkina Faso

French Polynesia

Laos

Mozambique

San Marino

Yemen

Burma

Gabon

Lebanon

N. Mariana Islands

Sao Tome & Principe

 

Burundi

Gambia

Lesotho

Namibia

Senegal