Last updated: March 11, 2024
I
Nrnb ltd. a company incorporated and acting under the laws
of
the
Republic of Seychelles (hereinafter – “Website”, “Service”, “Company”, "we", "our" or "us"),
a
company committed to fostering trust, integrity, and regulatory compliance. In the dynamic
landscape
of digital assets, we recognize the paramount importance of maintaining the highest
standards of
transparency, ethical conduct, and adherence to Anti-Money Laundering ("AML") and Know Your
Customer
("KYC") principles.
The Company places utmost significance on preventing and combating money laundering,
terrorist
financing, and other illicit activities. This commitment is rooted in our dedication to
creating
a
secure and trustworthy platform for our valued customers and partners.
Our commitment extends beyond mere compliance; it is a pledge to proactively contribute to
the
global efforts to curb financial crime and uphold the integrity of the financial system.
This AML/KYC policy ("AML/KYC Policy") is crafted to serve as a comprehensive framework that
guides
our operations and interactions.
We envision a future where transactions are conducted with the utmost security, integrity,
and
adherence to global regulatory standards. By implementing and continuously refining our
AML/KYC
Policy and procedures, we strive to be at the forefront of responsible innovation, setting
industry
benchmarks for ethical conduct and regulatory compliance.
This procedure confirms the absolute legality of the transaction carried out by you ("your",
"your",
"Customer") before the regulatory institutions. Therefore, you confirm that you are a
law-abiding
citizen and the state has no reason to address any claims towards you.
If you are from any of the high-risk and non-cooperative jurisdictions listed on the website
of
Financial Action Task Force (FATF), you will not be allowed to register as a Customer of
this
Website or use any service offered by this Website.
By accessing and using Company’s services and the Website, you acknowledge and declare that
you
are
not located in, or are not a citizen or resident of USA, Afghanistan, North Korea, Crimea
and
Sevastopol, Democratic Republic of Congo, Eritrea, Libya, Somalia, South Sudan, Sudan,
Yemen,
Iran,
Iraq, Cuba, Syria, Mali, Central African Republic, Guinea-Bissau, Lebanon or any other
country
subject to United Nations Security Council Sanctions List and its equivalent.
The Company may change this AML/KYC Policy at any time without any notice, effective upon
its
posting on the Website. Your continued use of the Website and services shall be considered
your
acceptance to the revised AML/KYC Policy.
For Law Enforcement requests please direct your official document to our compliance team at:
[email protected].
1.1. The primary objectives of our AML/KYC Policy are:
Ensure strict adherence to local and international AML/KYC regulations, fostering a lawful and trustworthy cryptocurrency platform.
Implement a robust Customer Identification Program (CIP) to verify user identities, ensuring the legitimacy of transactions.
Actively prevent money laundering and terrorist financing by employing stringent measures and risk assessments.
Conduct enhanced due diligence for high-risk customers, bolstering security measures where potential risks are identified.
Tailor our approach based on the assessed risk levels of customers, optimizing resource allocation for effective risk management.
Encourage prompt reporting of suspicious activities by all employees, facilitating swift investigation and reporting to authorities.
Regularly review and update policies to stay aligned with evolving regulations and industry best practices.
2.1. In accordance with regulatory requirements and our
commitment to
combating money laundering and other financial crimes, the Company has established a robust
Customer
Identification Program ("CIP"). The primary objective of this program is to ensure the
accurate
and
timely identification of our customers, thereby mitigating the risk of illicit activities
within
our
ecosystem.
2.2. The key components of our CIP are the following:
Customer Verification: the Company engages diligent measures to verify the identity of each customer, including but not limited to obtaining and cross-referencing valid government-issued identification documents, such as passports, national IDs, or driver's licenses;
Risk-Based Approach: Our CIP is built on a risk-based approach, allowing us to calibrate the level of identification procedures based on the assessed risk associated with each customer. This ensures that our due diligence efforts are proportionate to the perceived risk of money laundering or other illicit activities;
Ongoing Monitoring: We continuously monitor customer transactions, account activities, and any changes in customer behaviour. This ongoing monitoring enables us to promptly identify and respond to any suspicious or unusual patterns that may indicate potential financial crime;
Record Keeping: To comply with regulatory requirements, we maintain comprehensive records of customer identification information and transaction history. This documentation facilitates audits, regulatory examinations, and internal reviews.
2.3. Customers are expected to cooperate fully with the Company's CIP by providing accurate and up-to-date information upon request. Failure to do so may result in restrictions on account access or other necessary measures to mitigate potential risks.
3.1. The Company adopts a risk-based approach to its AML/KYC procedures. This approach is
designed
to effectively manage and mitigate the risks of money laundering, terrorist financing, and
other
illicit activities while allowing us to allocate resources efficiently.
3.2. We conduct regular risk assessments to identify and evaluate the inherent risks
associated
with
our products, services, customers, and geographic locations. This assessment forms the basis
for
tailoring our AML/KYC procedures to address specific risk factors.
3.3. Each customer undergoes a risk profiling process based on factors such as their
business
activities, transaction volumes, geographic location, and the nature of their relationship
with
the
Company. This profiling allows us to categorize customers into different risk levels: low,
medium,
or high.
3.4. For customers categorized as high risk, the Company applies enhanced due diligence
measures.
This may include obtaining additional information, conducting more frequent reviews, and
implementing heightened monitoring to ensure a thorough understanding of the customer's
activities.
3.5. We engage advanced transaction monitoring systems to detect and analyze unusual or
suspicious
patterns of activity. This real-time monitoring allows us to promptly investigate and take
appropriate action when potential risks are identified.
3.6. Our risk-based approach includes a periodic review of customer profiles to reassess
their
risk
level based on changes in their business activities, transaction patterns, or other relevant
factors. Adjustments to AML/KYC measures are made accordingly.
4.1. We are committed to maintaining the highest standards of
integrity and preventing our services from being exploited for illicit activities, including
money
laundering, terrorist financing, or other financial crimes. All employees are obligated to
report
any suspicions of such activities promptly and in accordance with the procedures outlined in
this
policy.
4.2. Every employee is expected to remain vigilant and alert to any unusual or suspicious
activities
that may indicate potential money laundering or other illicit behaviour. This includes
transactions
that deviate from the established norms, inconsistent customer behaviour, or any other red
flags
outlined in our training materials.
4.3. The Company provides a list of indicative red flags and suspicious activity indicators
to
guide
employees in recognizing potential risks. This list is regularly updated to reflect emerging
trends
and regulatory changes.
4.4. If an employee suspects or identifies a potentially suspicious activity, they are
required
to
report it immediately to the designated AML Officer or the appropriate department. The
report
should
include detailed information on the nature of the suspicion, relevant transaction details,
and
any
supporting documentation.
4.5. The Company ensures confidentiality in the reporting process. Employees who make
reports in
good faith will be protected against any form of retaliation. Retaliation against employees
reporting suspicions is strictly prohibited and will be subject to disciplinary action.
4.6. The AML Officer is responsible for receiving and reviewing all suspicious activity
reports.
If
necessary, the AML Officer will escalate the report to the appropriate authorities in
compliance
with applicable laws and regulations.
4.7. In addition to internal reporting, the Company acknowledges its responsibility to
report
suspicious activities to relevant regulatory authorities as required by law. We cooperate
fully
with
law enforcement agencies and regulatory bodies in their efforts to combat financial crimes.
The Company recognizes the critical importance of maintaining accurate and up-to-date records as an integral component of our Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance framework. This section outlines our commitment to comprehensive record-keeping practices to ensure transparency, facilitate regulatory oversight, and support ongoing due diligence.
6.1. The Company acknowledges the fundamental role of
employee
education and awareness in maintaining a strong defence against money laundering, terrorist
financing, and other illicit activities. This section outlines our commitment to ongoing
training
initiatives to foster a culture of compliance, vigilance, and accountability.
6.2. All employees, regardless of their role within the organisation, are required to
undergo
regular and comprehensive AML/KYC training programs. These programs cover relevant legal and
regulatory frameworks, our internal policies and procedures, and the identification of red
flags
and
suspicious activities.
6.3. New employees receive specialized AML/KYC training as part of their onboarding process.
This
training provides an overview of our AML/KYC policies, the importance of compliance, and
their
role
in safeguarding the integrity of our financial services.
6.4. Periodic updates and refresher courses are conducted to keep employees informed about
changes
in laws, regulations, and emerging trends related to AML/KYC. This ensures that our team
remains
current on best practices and industry standards.
6.5. The Company ensures that all AML/KYC policies and procedures are communicated clearly
to
employees. This includes providing access to policy documentation, guidelines, and any
updates
through accessible channels such as company intranets or training portals.
7.1. The Company is committed to maintaining a transparent
and
cooperative relationship with regulatory authorities to combat financial crimes effectively.
This
section outlines our dedication to working collaboratively with relevant agencies and
authorities to
uphold the highest standards of integrity and compliance.
7.2. While cooperating with authorities, the Company is committed to maintaining the
confidentiality
and security of sensitive information. We ensure that all information shared with regulatory
authorities is done in compliance with applicable data protection laws and regulations.
7.3. A record of cooperation with regulatory authorities, including communications, reports,
and
any
other relevant documentation, is maintained. This documentation supports transparency,
regulatory
compliance, and the demonstration of our commitment to effective collaboration.
7.4. By actively cooperating with regulatory authorities, the Company seeks to contribute to
the
broader efforts to combat financial crimes and maintain the integrity of the financial
system.
8.1. The Company designates a qualified and experienced individual as the AML Compliance Officer. The AML Compliance Officer is entrusted with the responsibility of overseeing, implementing, and enforcing the Company's AML and KYC policies and procedures. Key responsibilities include:
Regularly reviewing and updating the AML/KYC Policy to reflect changes in the regulatory environment and the Company's operations;
Ensuring that all employees are informed about and adhere to the AML/KYC Policy;
Conducting periodic risk assessments to identify and evaluate potential AML and KYC risks associated with the Company's products, services, and customer base;
Implementing risk-based procedures, including enhanced Due Diligence ("EDD"), for customers presenting higher risk profiles;
Overseeing the establishment and maintenance of the CIP to verify the identity of customers;
Ensuring that Customer Due Diligence ("CDD") procedures align with legal requirements and industry best practices;
Monitoring transactions and investigating any significant deviations from normal activity;
Developing and delivering AML/KYC training programs for employees to enhance awareness and understanding of compliance obligations;
Establishing channels for employees to report suspicious activities and ensuring that such reports are thoroughly investigated;
Maintaining open communication with relevant regulatory authorities and promptly reporting any suspicious transactions or activities as required by law;
Overseeing the maintenance of accurate and up-to-date records of customer information, transactions, and AML/KYC procedures for the required retention period;
8.2. The AML Compliance Officer operates with a high degree of independence and authority to effectively carry out their responsibilities. They have direct access to senior management and the Board of Directors, ensuring that AML and KYC concerns are elevated and addressed at the highest levels of the organisation.This policy will undergo periodic reviews to ensure its effectiveness and compliance with evolving regulatory requirements. Updates will be made as necessary, and employees will be informed of any changes