AML/KYC POLICY
Know Your Customer and Anti-Money Laundering policies for a secure platform
Table of Contents
This document gives an overview of the standards of the "Know Your Customer" and "Anti-Money Laundering" policies, thereby setting our practices for the prevention of money-laundering activities while dealing with our users.
Our Commitment: The objective of AML/KYC Policy is to prevent SwapRocket from being used, intentionally or unintentionally, by criminal elements for money-laundering activities. The Policy also mandates making reasonable efforts to determine the true identity and beneficial ownership of accounts, source of funds, the nature of customer's business, the reasonableness of operations in the account in relation to the customer's business, etc., which in turn helps us to manage its risks prudently.
We strive to protect our customers from fraudulent and scam activities in the crypto assets sphere. SwapRocket employs a steadfast approach in the implementation of the latest recommendations and revised guidelines by FATF, European Parliament, and regulators of the financial industry by and large. Our in-compliance policy stance is designed to detect funds proven to be involved in illicit activities as well as to protect the funds of our customers who have fallen victims to hacks, ransomware and malware attacks. The toolkit at work committed to fighting money laundering and its implications is comprised of policy regulations in conjunction with recent developments in software aimed at tracking suspicious transactions in real time.
Glossary
AML
Anti-Money Laundering
KYC
Know Your Customer
CIP
Customer Identification Program
PEP
Politically Exposed Persons
STR
Suspicious Transaction Reporting
SAR
Suspicious Activity Reporting
The Policy covers the following matters:
1. Customer Identification Procedure (CIP)
Our process for verifying the identity of users in situations requiring enhanced scrutiny.
2. Recordkeeping
How we securely store and maintain user verification information and transaction history.
3. AML Compliance Officer
Our designated officer responsible for implementing and monitoring AML policies.
4. Monitoring of Transactions
Our system for detecting and analyzing suspicious transaction patterns.
5. Risk Management
How we assess and mitigate money laundering risks in our platform.
6. Collaboration with Law Enforcement
Our procedures for cooperating with relevant authorities.
1Customer Identification Procedure (CIP)
CIP applies to transactions that are spotted by our scoring system as suspicious. We will collect certain customer identification information from each customer who passes CIP; utilize risk-based measures to verify the identity of each customer who passes CIP; record customer identification information and the verification methods and results; provide adequate CIP notice to customers that we will seek identification information from to verify their identities.
a. Identification
In case a transaction is spotted by our risk scoring system as suspicious, the transaction will be put on hold, and we will collect the following information from the customers, if applicable, from any person, entity, or organization:
b. Customers Who Provide Misleading Information
After providing the information, the customer must ensure that the information is true, complete, and timely updated. If there are any grounds for believing that any of the information customer provided is incorrect, false, outdated, or incomplete, we reserve the right to send the customer a notice to demand correction and, as the case may be, blacklist the existing account and terminate all or part of the services we provide for the said customer.
c. Verifying Information
Based on the risk, and to the extent reasonable and practicable, we will proceed with the verification to the extent that we have collected all information needed in order to know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers.
2Recordkeeping
We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process.
According to the documentation of Sum Substance, all User data obtained during the KYC procedure is encrypted and stored on GDPR-compliant Amazon servers, which are located in the EU. These are kept at Uptime Institute classified Tier III data centers compliant with TIA-942 and PCI DSS standards. The data centers are protected technically and guarded physically around the clock by specially audited security personnel.
We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer's identity for five years after the record is made.
The above-mentioned records can be made available to the competent authorities upon request.
3AML Compliance Officer
The AML Compliance Officer is the person, duly authorized by SwapRocket, whose responsibility is to implement and effectively monitor the application and enforcement of the AML/KYC policy as outlined in this document. The AML Compliance Officer is obliged to oversee and conduct effective monitoring of all aspects of SwapRocket's anti-money laundering and counter-terrorist financing. Any suspicious behavior or activities should be reported to the AML Compliance Officer.
Communication with the AML Compliance Officer in regards to this Policy is conducted via:support@swaprocket.io
4Monitoring of Transactions
Ongoing monitoring is an essential element of effective KYC procedures. We have an understanding of the normal and reasonable activity of the customer, ensuring that we have the means of identifying transactions that fall outside the regular pattern of activity. However, the extent of monitoring will depend on the risk sensitivity of the account. High-risk accounts have to be subjected to intensified monitoring. In case of sudden swaps of big amounts, these accounts can be flagged by the risk scoring system as low, medium, or high risk
We have implemented a Know-Your-Transaction service that is the real-time anti-money-laundering compliance solution for monitoring cryptocurrency transactions. As a result of its targeted approach, it empowered our SwapRocket compliance team to significantly speed up the detection of transactions with fraudulent funds involved.
5Risk Management
We have put in place appropriate procedures to ensure the effective implementation of KYC guidelines. The implementation procedure covers proper management oversight, systems and controls, segregation of duties, training, and other related matters. From time to time, the SwapRocket compliance team will carry on the necessary quality checks and file audits to ensure that the KYC policies and procedures are adhered to. From time to time, the SwapRocket compliance team shall update senior management about issues arising during the customer acquisition process.
6Collaboration with Law Enforcement Agencies
We obtain and hold required and accurate originator information and required beneficiary information on virtual asset transfers and make it available to appropriate authorities on official request
Have questions about our AML/KYC policies?
Our compliance team is ready to help clarify any points