Spectrum change

AML/KYC terms

Recommended for review by every user of the Spectrum Change exchange service. In case of disagreement with the provisions of this regulation, it is prohibited to use the services of the site.

1. Terminology

1.1. An online resource is an organization that provides services for the exchange of digital currency assets.

1.2. User / Client - a private or legal person, a party that accepts a number of services offered on the site platform.

1.3. Illegal activities related to digital money include the following concepts:

  • money laundering;
  • all types of fraudulent activities;
  • concealment or concealment of the actual purpose of finance, the receiving side, aspects of the transfer;
  • investing in terrorist organizations;
  • financing the distribution of narcotic substances, weapons, ammunition and other activities of an illegal nature that are contrary to the criminal code of the current legislation.

1.4. Sub-sanctioned person - a user who is under the influence of restrictions or fines imposed by the EU countries, the UN and other organizations or the government to resolve conflict situations.

1.5. PEP is a person of political significance who conducts special activities in the state system. Instructions regarding this person will also be imposed on members of his inner circle (family of relatives).

1.6. The AML policy is an activity aimed at recognizing the illegality of income declarations.

2. General provision

2.1. This regulation was developed on the basis of the law on AML and the provision on sanctions of international order in the framework of their application to resolve domestic situations.

2.2. The code and rules of the policy allow you to define methods for the safe organization of work and conduct of activities.

2.3. The events are aimed at checking and identifying situations related to illegal activities in the field of virtual currency, conducting unusual and non-standard transactions.

2.4. Appropriate action is taken in cases where a client"s activity is classified as suspicious/illegal.

2.5. The regulation is a legal instruction for the employees of the online resource for the sequence of actions when checking suspicious transactions and users.

2.6. Each employee is personally responsible for the compliance of actions in the work with the norms of the legislative order.

3. Terms of communication with the user

3.1. The administration of the online resource in all relations with the client uses the provisions of the regulation.

3.2. Website employees do not conduct business with representatives of individuals.

3.3. Each user agrees and also undertakes to undergo an identification procedure. Identification takes place subject to certain rules.

4. Identification regulation

4.1. The user provides the following information: last name, first name, patronymic.

4.2. Information about citizenship.

4.3. Passport data, including full data specification.

4.4. Detailed information about the date and place of birth.

4.5. Registration data, as well as the current place of residence.

4.6. Various contact information, including postal and electronic addresses, telephone numbers.

4.7. Any contacts for communication.

4.8. Photocard of civil and/or foreign passport, ID-card.

4.9. A photo of a user holding a document that proves their identity.

4.10. A photographic representation of bills for the provision of services by utilities, indicating the actual address of the user. The request is necessary in the case when the identity document does not contain information about the place of residence or registration.

4.11. Driver"s license.

4.12. A direct or indirect affiliation of a PEP person is requested. Any involvement with a person who performs the functions of a PEP must be indicated.

4.13. Other personal information in any volume and format that the online resource classifies as necessary to fully identify the user.

4.14. If the client is a legal entity, then additional documentation will be required to identify it:

  • extract from the commercial register (deadline for receipt - no later than 3 months from the date of the request);
  • name, registration number, date of registration of the organization;
  • valid and legal address;
  • information about representatives, co-founders, beneficiaries, taking into account their contact information.

5. Possible risks and conditions of cooperation

5.1. In cooperation with the user, the online resource calculates possible risks in relation to the laundering of digital currency and illegal activities related to finance.

5.2. The parameters that are the target for verification are:

  • location location;
  • the risk that comes from the client himself;
  • possible transactions with the user.

5.3. The risks associated with the location are high in the case of transactions in the following territories:

5.3.1. UN and EU sanctioned places.

5.3.2. Countries that do not counteract illegal transactions in the financial sector.

5.3.3. States that are known to conduct illegal currency transactions, invest in terrorism, and countries with a high level of corruption.

5.4. Client-related risks are suspect in the following cases:

5.4.1. The user is a PEP or is directly or indirectly related to a PEP person.

5.4.2. Inclusion in the sub-sanctions list as an unreliable user. This information is tracked and identified.

5.4.3. The person is directly related to actions that are illegal in the financial sector.

5.5. Risks associated with possible transactions are considered significant in the following cases:

5.5.1. Making transactions by a third party.

5.5.2. Unreasonable conclusion of transactions.

5.5.3. Hiding current members from public view.

5.5.4. Receipts of assets from various accounts.

5.5.5. Non-standard receipt of currency.

5.5.6. Transfer of assets having different denominations in each case of transactions.

5.6. Each of these reasons is a possible risk and reason to consider the user unreliable.

5.7. The online resource has the right to refuse cooperation in the following situations:

5.7.1. The user is directly related to states with high risk scores.

5.7.2. The client is under international sanctions received as a result of illegal actions in the financial sector.

5.7.3. With a direct or indirect relationship to the person PEP.

5.7.4. If there is evidence or suspicion of illegal operations by users before. In this case, enhanced measures are taken regarding the verification and identification of the client.

6. Digital risks and their detection

6.1. Digital risks are defined by the following actions:

  • transfer of any information to third parties;
  • provision of deliberately false, inaccurate, erroneous data;
  • the introduction of viruses;
  • organization of hacker attacks;
  • implementation of activities associated with risks in the work for the system.

6.2. In the fight against risks, the employees of the online resource take the following actions:

  • use exclusively internal servers;
  • use software on a legal basis with approved content;
  • use techniques that are not integrated with external sources.

6.3. In the fight against the risks associated with receiving inaccurate, false, erroneous data from the user, the online resource has the right to require confirmation of personal data through video communication, a real meeting, requesting additional documents to confirm identity.

6.4. In the fight against the risks associated with cyber attacks, the online resource takes the following actions:

  • the system is constantly tested for the reliability of transactions;
  • security is tested;
  • the software is constantly updated, preventive measures are taken to counter the introduction of viruses.

6.5. To reduce the likelihood of risks and eliminate them during data processing, the online service has the right to use server fuses and make backups.

6.6. The system is PCI/DSS certified.

7. Due diligence conditions

7.1. The application of due diligence at a comprehensive level is carried out in relation to users with suspicion of conducting illegal transactions that are of a non-standard nature and include complex schemes.

7.2. The set of measures includes:

  • conducting user identification based on all documentation, video communication or personal meeting;
  • verification of participants in the transaction;
  • business relationship research;
  • verification of the source of receipt of digital currency;
  • continuous monitoring and regular verification of the data provided;
  • request for data from registers.

7.3. Comprehensive verification is expected and carried out before the start of cooperation.

7.4. Identification of the user"s identity is carried out at the initial stage.

7.5. If suspicions are identified, appropriate action is taken immediately.

8. Extended Check Conditions

8.1. Legal verification in an extended format is carried out in the following cases:

  • the user submitted data from a location where, in fact, it cannot be;
  • due diligence aroused suspicion;
  • it is not possible to fully identify the client or participants in transactions;
  • circumstances are subject to a high risk of illegal transactions.

8.2. The possibilities of online resources in this case are as follows:

8.2.1. Verification of user information against the register of credit institutions operating in the territory regulated by AML rules. The case is relevant when the client is related to this institution.

8.2.2. Confirmation of authenticity of data by means of electronic delivery of information.

8.2.3. Organization of payment with the participation of credit institutions in a country where AML / KYC policy protocols are in force.

9. PEP test conditions

9.1. A user who is a PEP or who is directly or indirectly related to a PEP person must indicate this in the registration form (there is a mandatory field for verifying information). The information will be checked against shared sources.

10. Conditions for verification of sanctioned persons

10.1. A user who is a person subject to international sanctions is required to enter this information when filling out the registration form. To enter into a business relationship with an online resource, this information will be verified during identification.

11. Verification conditions in case of suspected illegal transactions

11.1. Suspicious factors include:

  • cases of discrepancy between the appearance and behavior of the user;
  • impossibility of independent signing of documents;
  • suspicion of illegal activity in the present or in the commission of similar acts earlier;
  • the impossibility of proving the need for action;
  • groundlessness of high parameters of the value of the transaction;
  • non-standard transactions;
  • the presence of various operations in the financial sector that are not related to the activities of the user;
  • digital currency is transferred to third-party accounts and to other states;
  • lack of argumentation regarding transactions;
  • unusual activities of the client related to the exchange of virtual currency and the compliance of his business;
  • inability to pass personal identification;
  • unwillingness to provide personal data;
  • an attempt to conduct a fake transaction;
  • requirements for the organization of settlements exclusively in cash monetary assets;
  • financial actions in the interests of third parties;
  • settlement with the participation of a bank located in a tax-free territory.

11.2. To enter into a business relationship with an online resource, the user undergoes a detailed check.

12. Collection, analysis and storage of data

12.1. For 5 years, the online resource can store the following information after the completion of cooperation with the user:

  • data for identification, their verification;
  • correspondence with the client;
  • information relating to the monitoring of user activity;
  • data on the presence of suspicious and non-standard transactions;
  • all records relating to transactions and procedures associated with them.

12.2. The collection, analysis and storage of data is carried out within the framework of the privacy policy.

12.3. Additional processing and seizure may be carried out in case of suspicion of illegal activities. Such information is reported to the MLRO (Money Laundering Reporting Officer).