Anti-Money Laundering and Prevention of Crime Policy
1. Aim of Anti Money Laundering and Crime Prevention Policy
The aim of Anti Money Laundering and Crime Prevention Policy is to:
- define the policy and procedures in relation to risk assessment and management
- involve a number of discrete steps in assessing how to manage and mitigate the money laundering and terrorist financing risks faced by Coindoodle Limited (“Coindoodle” or the “Company”)
- increase transparency of financial transactions of the Company.
2. The meaning of money laundering
According to Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, the following conduct, when committed intentionally, shall be regarded as money laundering:
- the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
- the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
- the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;
- participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points above.
Money laundering in cryptocurrency trading sector may occur due to:
- the anonymity of virtual currencies which allows their potential misuse for criminal purposes
- exchanging money, assets, goods and property that were acquired criminally for money or assets that appear to be legitimate or clean, achieved by transferring or passing the funds through some form of legitimate business transaction or structure;
3. Violation of AML
Offences in relation to money laundering include:
- concealing criminal property;
- acquiring, using or possessing criminal property;
- entering into or becoming concerned in an arrangement which the person knows or suspects facilitates the acquisition, retention, use or control of criminal property;
- tipping off a person that a report has been made.
4. Customer Due Diligence
Customer due diligence measures include:
- identifying the customer and verifying the customer's identity on the basis of documents, data or information obtained from a reliable and independent source;
- identifying the beneficial owner and taking reasonable measures to verify that person's identity so that the obliged entity is satisfied that it knows who the beneficial owner is, including, as regards legal persons, trusts, companies, foundations and similar legal arrangements, taking reasonable measures to understand the ownership and control structure of the customer;
- assessing and, as appropriate, obtaining information on the purpose and intended nature of the business relationship;
- conducting ongoing monitoring of the business relationship including scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the obliged entity's knowledge of the customer, the business and risk profile, including where necessary the source of funds and ensuring that the documents, data or information held are kept up-to-date.
Identifying a customer means obtaining information about his identity (name, address, date of birth, employment and financial history, physical appearance and family circumstances).
Verifying identity means obtaining evidence that supports this information. It is generally considered good practice to require either:
- one government document which verifies either name and address or name and date of birth; or
- a government document which verifies the customer’s full name and another supporting document which verifies their name and either their address of date of birth.
Customer due diligence is carried out to identify and verify the identity of all customers who approach the threshold set out in point 5.2 of this document. The Company is aware that customer due diligence is ongoing and may need updating where there are changes in a customer’s circumstances and personal details. The customer due diligence process is complete when a customer provides the Company with his name, residential address, photo and date of birth Identification Documents.
Records of customer due diligence are kept for 5 years from the end of the business relationship or the customer’s last visit to the Company.
4.1 Customer Registration
In order to open an account at the web portal www.coindoodle.com a customer must first complete the registration process.
The registration details to be filled in by all new customers include the username, password, first and last name, e-mail address and account currency. When a new account is created, a verification link is sent to the email account specified during the registration process. When the user clicks on the link the account is then successfully created.
4.2 Threshold approach
In the threshold approach, verification is required if the amount of money deposited is equal to or higher than €1,000.
The identity of the user must be verified before or immediately after such payment or stake takes place.
If customer due diligence cannot be completed for any reason, the customer will not be allowed access to cryptocurrency exchange, no transactions with the customer will be carried out, and the business relationship will be terminated.
4.3 Documentary evidence
Coindoodle relies upon documents issued by government departments during customer due diligence.
To fulfil the necessary customer identification and verification process, the Company requires its customers to upload on their websites a copy of valid identification documents. This request is communicated to the customer via the registered email address. If necessary, the customer may be contacted by phone to further facilitate and enable the verification process. If documents are in a foreign language, the Company takes appropriate steps to be reasonably satisfied that the documents provide evidence of the customer’s identity, for example, by obtaining a translation of the relevant sections. Such a step would be to request that the customer provide the documents with a certified true translation.
Only documents issued by government departments and agencies that contain a photograph are considered reliable to verify the customer’s identity. Government issued documents without a photograph may be used to confirm the current address of the customer (if stated on the document).
The following sources may be accepted for verification of customers:
- current passport;
- birth certificate;
- current photo card driving licence;
- residence permit issued by the Home Office;
- firearms certificate or shotgun licence;
- benefit book or original notification letter from the Department of Works and Pensions confirming the right to benefits;
- council tax bill;
- utility bill or statement (but not ones printed off the internet), or a certificate from a utilities supplier confirming an arrangement to pay services on pre-payment terms;
- bank, building society or credit union statement or passbook containing current address (but not statements printed off the internet) - bank or credit cards alone will not be sufficient as these do not provide either residential address or date of birth;
- confirmation from an electoral register that a person of that name lives at that address;
- recent original mortgage statement from a recognised lender;
- solicitor’s letter confirming recent house purchase or land registry confirmation of address;
- local council or housing association rent card or tenancy agreement;
- HM Revenue and Customs (HMRC) self-assessment statement or tax demand;
- house or motor insurance certificate.
4.4 Enhanced due diligence
Enhanced due diligence measures and enhanced ongoing monitoring must be carried out, in addition to the customer due diligence measures, if applicable:
- when the customer is not present, which is relevant to an online operation this would only be relevant for the online operations;
- if a customer is a politically exposed person (“PEP”), or a family member or known close associate of a PEP;
- in any other situation where the customer presents a higher risk of money laundering or terrorist financing (e.g. a high spending customer);
- if any business relationship or transaction with a person established in a high-risk country;
- in any case where: a/ transaction is complex and unusually large, or there is an unusual pattern of transactions; and b/ the transaction or transactions have no apparent economic or legal purpose; in any case where a customer provided false or stolen identification documentation or information.
- identification documents provided by the customer (e.g. passport, driving licence, utility bill);
- business cards provided by the customer;
- information provided by the customer in conversation;
- verification of identity using an online provider;
- third party acuity and wealth reports;
- credit reports;
- information available in the media and on the internet;
- search of PEP databases;
- company registration searches for companies the customer appears to be a shareholder or officer of.
- at the point that verification is triggered, the Company puts all monies owed to the customer into an account (or equivalent) from which no withdrawals can be made;
- further deposits can be made to that account as long as they too are ‘locked’ into it until CDD is completed;
- once CDD is completed, the account can be ‘unlocked’ and business can continue as normal;
- if CDD cannot be completed, then the Company will terminate the business relationship with the customer;
- if there are monies to be repaid, the amount repaid will consist of the monies owed to the customer at the point that the verification procedure was triggered plus all deposits made at that point and thereafter;
- money will be returned to the originating account;
- there will be appropriate risk mitigation.
- multiple destinations - is the customer requesting that the money be sent to several bank accounts?
- high risk destination - is the customer requesting that the money be returned to a country where there is a significant money laundering concern?
- unusual patterns and large transactions - is there an apparent economic or lawful purpose behind the transactions?
- very high account turnover - is the turnover consistent with the balance?
- irregular activity - are the transactions outside of the customer’s regular transaction activity?
- what risk is posed by the business profile and customers using the website?
- is the business high volume consisting of many low spending customers?
- is the business low volume with high spending customers?
- is the business a mixed portfolio? Are customers a mix of high spenders and lower spenders and/or a mix of regular and occasional customers?
- is the business local with regular and generally well known customers?
- are there a large proportion of overseas customers using foreign currency?
- are customers likely to be individuals who hold public positions in other countries?
- are customers likely to be engaged in a business which involves significant amounts of cash?
- are there likely to be situations where the source of funds cannot be easily established or explained by the customer?
- customer interactions - Details of all customer interactions and relationships including which employee dealt with the interaction, what was asked, why an interaction was made and the outcome of the interaction;
- risk-based approach - Details of steps taken to manage and mitigate risks of crime and disorder;
- customer identification and verification information, including copies of any enhanced due diligence documentation.
In relation to PEPs and other customers that present a higher risk of money laundering or terrorirst financing, the Company will seek to obtain evidence of the customer’s source of funds. This evidence may include:
The Company will use a mix of sources, including external sources and information taken directly from the customer, for EDD purposes.
4.5 Requirements procedures
In the light of the requirements imposed by the relevant regulations, the Company, adopt the following procedure when customer due diligence is triggered under the threshold approach:
4.6 Risk assessment
Risk assessments are undertaken which include the following:
The assessment of risk carried out by the Company is based on a number of factors and questions including:
4.7 Failure to complete checks
If customer of the Company is unable to comply with or complete the required customer due diligence or enhanced due diligence, the Company will not carry out a transaction with or for the customer through any of the available payment methods. Instead, the customer’s account at cryptocurrency exchange will be terminated .
5. Ongoing Monitoring
Monitoring customer activity is carried out using the risk-based approach, with higher risk customers, such as PEPs, being subjected to an appropriate frequency and depth of scrutiny, which is likely to be greater than is appropriate for lower risk customers.
6. Record Keeping
The Company will keep records of the following:
These records will be kept for a period of at least 5 years.
Where an employee of the Company has received information, as a result of which they know or suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in money laundering or terrorist financing, that employee must make an internal report.
8. Collusion and cheating
The Company has systems to detect cheating, collusion or illegal activity, including suspicious and large transaction alerts, risk management solutions to monitor customer transaction and online risk solutions. Where suspicious activity is identified, the customer’s account will be reviewed. The customer’s account will be suspended and where cheating/collusion is identified, the account will be closed and the customer will be reported to the NCA, where it is deemed necessary.
If an employee is implicated in any cheating, collusion or other illegal activity, they will be suspended pending a full investigation.
Information clause for COINDOODLE Limited users:
The safety of our Clients is the most important value for our team. We are a company operating not only on the basis of appropriate legal instruments, but above all on high ethical standards. We care about the building of mutual trust, which is the decisive factor in your satisfaction and our condition, transparency and care for the safety of you - our clients first and foremost. Implementing the above principles as well as the provisions of Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. We would like to inform you who, how and on what basis processes your personal data.
Due to the constant fluctuations of the value of cryptocurrencies, investing in this sector is associated with the risk of loss. It is not possible to make profit on cryptocurrencies without the risk of losing invested money. It is important to be aware that cryptocurrencies market is variable and even small change in the price of currency may cause significant losses. Coindoodle shall not be liable for any potential loss resulted from value fluctuations.