AML / KYC Policy


KUNDERBANK Anti-Money Laundering and Know Your Customer Policy (hereafter "the AML / KYC policy") is designed to prevent and mitigate the possible risks of KUNDERBANK being involved in any kind of illegal activity.

Both international and international regulations require KUNDERBANK to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drugs and human trafficking, the proliferation of weapons of destruction mass, corruption and corruption and to act in the event of any form of suspicious activity by its users.

The AML / KYC policy covers the following aspects:

  1. Verification procedures
  2. Compliance Officer.
  3. Monitor transactions.
  4. Risk assessment.

1. Verification Procedures

One of the international standards for the prevention of illegal activity is the Customer Due Diligence ("CDD"). According to CDD, KUNDERBANK establishes its own verification procedures under the anti-money laundering and "Know Your Customer" standards.

1.1. Identity verification

The KUNDERBANK identity verification procedure requires the User to provide KUNDERBANK with independent and reliable documents, data or information of origin (eg national ID, international passport, account statement, bill). To this end, KUNDERBANK reserves the right to collect user identification information for the purposes of the AML / KYC policy.

KUNDERBANK will confirm the authenticity of the documents and information provided by users. All legal methods for the double checking of identification information will be used and KUNDERBANK reserves the right to investigate certain Users who have been determined to be risky or suspicious.

KUNDERBANK reserves the right to verify the identity of the User on an ongoing basis, in particular when his identification information has been changed or their activity has seemed suspicious (unusual for the particular User). In addition, KUNDERBANK reserves the right to request updated documents from Users, even if they have passed identity verification in the past.

User identification information will be collected, stored, shared and strictly protected in accordance with the KUNDERBANK 's privacy policy and related regulations.

Once the identity of the user has been verified, KUNDERBANK is able to remove itself from a potential legal liability in a situation where its Services are used to carry out illegal activities.

1.2. Card verification

Users who intend to use payment cards in connection with the KUNDERBANK Services must pass the card verification in accordance with the instructions available on the KUNDERBANK website.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by KUNDERBANK, who is responsible for ensuring the effective implementation and application of the AML / KYC policy. It is the responsibility of the Compliance Officer to oversee all aspects of KUNDERBANK's anti-money laundering and anti-terrorism funding, including but not limited to:

a. Collection of user identification information. b. Establish and update internal policies and procedures for the completion, review, presentation and preservation of all reports and records required by applicable laws and regulations. c. Monitor transactions and investigate any significant deviations from normal activity. d. Implementation of a record management system for the appropriate storage and retrieval of documents, files, forms and records. is. Periodic update of the risk assessment. f. Provide law enforcement agencies with the information required by applicable laws and regulations.

The Compliance Officer has the right to interact with law enforcement agencies, which are involved in the prevention of money laundering, terrorist financing and other illegal activities.

3. Monitor transactions

Users are known not only by verifying their identity (who they are) but, above all, by analyzing their transactional patterns (what they do). Therefore, KUNDERBANK is based on data analysis as a tool for assessing risks and detecting suspects. KUNDERBANK carries out a series of compliance-related activities, including data acquisition, filtering, record keeping, investigation management and reporting. System features include:

1) Daily control of users against recognized "black lists" (eg OFAC), aggregation of transfers from multiple data points, placement of users on the lists of supervision and assistance denialists, opening of cases for investigations where necessary , sending internal communications and filling in statutory reports, if applicable;

2) Case and document management.

Regarding the AML / KYC policy, KUNDERBANK will monitor all transactions and reserves the right to:

  • to ensure that suspicious transactions are reported to the appropriate law enforcement agencies through the Compliance Officer;
  • require the user to provide additional information and documents in case of suspicious transactions;
  • suspend or terminate your account when KUNDERBANK reasonably suspects that such User is involved in illegal activities.

The list above is not exhaustive and the Compliance Officer will monitor the Users' transactions daily in order to define whether such transactions should be reported and treated as suspicious or to be treated as in good faith.

4. Risk assessment

KUNDERBANK, in line with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, KUNDERBANK is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be addressed according to priorities so that the greatest risks receive the greatest attention.

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