Kunava AML POLICY
Effective date: February 21th, 2024
1. Introduction
This Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) policy outlines the guidelines and procedures implemented by Elevate Eco s.r.o., a company registered at Cimburkova 916/8, Žižkov (Praha 3), 130 00 Praha (“Company”), operating a cryptocurrency exchange platform https://kunava.io (the “Platform”).
2. Purpose
This policy (the “Policy”) is designed to keep the Company’s activity on the Platform in compliance with the laws of the Czech Republic, European Union and international regulations in order to prevent money laundering, terrorist financing, and other illicit activities. The purpose of this Policy is to establish a framework for conducting thorough due diligence on customers, monitoring transactions, and reporting suspicious activities. By implementing strong KYC and AML measures, the Company aims to protect its Platform, customers, and the integrity of the financial system.
3. Application of “Know Your Customer” Principles
By implementing the following principles, the Company aims to mitigate the risks associated with money laundering, terrorist financing, and other illicit activities:
1) Customer Identification and Verification:
During the customer registration process, the Company collects and verifies the necessary information and documentation to establish the identity of each customer. To ensure the authenticity and validity of the provided identification documents, the Company employs robust document verification procedures. The Company applies a risk-based approach to customer identification and verification. This involves assessing the level of risk associated with each customer based on various factors, including the customer's profile, transaction history, and jurisdiction from which the customer comes.
2) Ongoing Monitoring and Due Diligence:
The Company implements robust transaction monitoring systems to detect suspicious activities and identify unusual transaction patterns. In cases where enhanced due diligence is necessary, the Company conducts additional verification procedures and collects further information from customers. To ensure the continued compliance of customers and their activities, the Company conducts periodic reviews of customer accounts and updated due diligence.
3) Reporting Suspicious Activities:
The Company trains its employees to identify and report any suspicious activities promptly. If any suspicious activity is detected, the Company adheres to its legal obligations and promptly reports such activities to the appropriate regulatory and law enforcement authorities.
4) Compliance Audit:
The Company conducts regular internal and external audits to assess the effectiveness and compliance of its KYC procedures.
4. Customer Identification Procedure
4.1. Customer Identification
The Company requires all users to undergo a comprehensive customer identification process in the course of account registration. Pursuant to the rules, the following standard package of information and documentation will be collected, verified and authenticated:
a) Individual Customers:
1) Email address;
2) Mobile phone number;
3) Customer’s full name;
4) Personal identification code, if not available, date and place of birth;
5) Residence or domicile;
6) Date and place of birth;
7) Nationality;
8) Citizenship;
9) Other information at the discretion of our Compliance Team;
10) Government-issued identification document (e.g., passport, ID card, driving license);
11) Proof of address (e.g., utility bill, bank statement);
12) Other documents at the discretion of our Compliance Team.
The list of information and documentation in not exhaustive, depends on a number of factors and may be supplemented from time to time, in which case the Effective date of the Policy is modified.
b) Corporate Customers:
1) Email address;
2) Mobile phone number;
3) Legal name;
4) Registration code;
5) Registered address;
6) Business address;
7) Incorporation details;
8) Information on the legal form and legal capacity of the authorized person;
9) The data on the members of the management board and nature of their representative right to represent the legal entity;
10) The data on the representatives;
11) The data on the actual beneficial owners;
12) Other information at the discretion of our Compliance Team;
13) Proof of legal existence, good standing of the legal entity and other legal documents (e.g. business registry extract, certificates, articles of association);
14) Identification documents of beneficial owners and directors;
15) Proof of address;
16) Other documents at the discretion of our Compliance Team.
The list of information and documentation in not exhaustive, depends on a number of factors and may be supplemented from time to time, in which case the Effective date of the Policy is modified.
4.2. Enhanced Due Diligence (EDD)
In certain cases, the Company may apply enhanced due diligence measures to customers who pose a higher risk, such as politically exposed persons (PEPs), high-value transactions or operating from a high-risk third country. This may include additional verification steps, request for source of funds documentation, and further ongoing monitoring by the Compliance Team.
5. Transaction Monitoring
5.1. Real-Time Monitoring
The Company employs advanced transaction monitoring tools to detect and analyze suspicious activities. These tools continuously monitor transactions, account behavior, and patterns associated with money laundering or terrorist financing.
5.2. Transaction Reporting
If any suspicious activity is detected, the Company will promptly report it to the relevant authorities in compliance with the laws of the Czech Republic and international regulations.
6. Record Keeping
The Company maintains detailed records of all customer identification information, transaction data, and communications for a minimum period of 5 years, unless a longer retention period is required by law, regulation or precept. These records are securely stored and readily available for audit and regulatory purposes.
7. Staff Training
All employees and relevant personnel of the Company undergo regular comprehensive training on AML and KYC policies and procedures. The trainings ensures that they are aware of their responsibilities and can effectively identify and report any suspicious activities.
8. Compliance Officer
The Company appoints a designated Compliance Officer responsible for overseeing the implementation and adherence to AML and KYC policies. The Compliance Officer ensures that the Company remains up to date with regulatory requirements and promptly reports any concerns or suspicions to the appropriate authorities.
9. Third-Party Relationships
When engaging in business relationships with third parties, the Company obliges such third party to adhere to the AML and KYC processes to the same extent as outlined in this Policy and as guided by the Compliance Team to ensure that these entities also comply with AML and KYC regulations. Ongoing monitoring and periodic reviews are conducted to assess the compliance of the third parties involved by the Company.
10. Periodic Review
This Policy is subject to periodic review to ensure its effectiveness and compliance with changing regulations and best practices. Updates and amendments will be implemented as necessary. The effective date represents the date from which the latest version of this policy is in effect. Any changes to the effective date will be clearly indicated at the beginning of this document.