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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.

 

AjuBit Limited (the AjuBit) pays thorough attention to any activities that may be considered as money laundering or terrorist financing. AjuBit 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/or terrorist financing, AjuBit implemented effective internal measures and procedures:

     • Establishment of the identity of AjuBit customer;

     • Assessment of risk;

     • Monitoring of the customer’s activities; and

     • Reporting of suspicious activities to respective authorities if necessary or asked hereby.

 

Establishment of the identity

Before any customer can access and benefit of AjuBit services, identity of such customer has to be established.

For AjuBit to be able to establish the identity of its customer, AjuBit 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 AjuBit 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. AjuBit retains a right to re-establish the identity of the customer in cases where AjuBit 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 AjuBit’s Privacy Policy and related regulations.

 

Assessment of risk

To mitigate and minimize the risks, AjuBit has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which AjuBit 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.

 

Monitoring

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

AjuBit uses both manual and automated solutions to track its customers’ transactions. AjuBit 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. AjuBit is entitled to request additional information/data/documents in relation to any transaction and the customer must follow the such request.

 

Reporting to the authorities

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

 

Compliance officer

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