AML/KYC Policy
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Anti-money Laundering and Know Your Customer Policy

The purpose of the BigPay Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is to identify, prevent and mitigate possible risks of BigPay being involved in illegal activity.

In conformity with international and local regulations BigPay has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users. AML/KYC Policy includes Verification procedures, Compliance Officer, Monitoring Transactions, Risk Assessment. Customer due diligence (“CDD”) has become one of one of the international standards for preventing illegal activity. Thus, BigPay has implemented its own verification procedures within the rigorous standards of anti-money laundering and “Know Your Customer” procedures.

The BigPay identification procedure requires the User to provide BigPay with reliable, independent source documents, data or information (for example, a national ID card, an international passport, an extract from the bank, a utility bill). For such purposes, BigPay reserves the right to collect the User’s identification information for the purposes of AML / KYC Policy compliance. BigPay will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used, and BigPay reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious. BigPay reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, BigPay reserves the right to request from the Users current documents, even if they have been authenticated in the past.

Information about the user’s identification will be collected, stored, shared and protected strictly in accordance with the BigPay Privacy Policy and relevant rules. After confirming the identity of the user, BigPay may refuse potential legal liability in a situation where the company’s services are used to conduct illegal activities.

The Compliance Officer is the person, duly authorized by BigPay, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

The Users are known not only by verifying their identity by analyzing their transactional patterns. Therefore, BigPay relies on data analysis as a risk-assessment and suspicion detection tool. BigPay performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities inсlude:

  • Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  • Case and document management.
  • In connection with the AML/KYC Policy, BigPay will monitor all transactions and it reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; request the User to provide any additional information and documents in case of suspicious transactions; suspend or terminate User’s Account when BigPay has suspicion that such User engaged in illegal activity.

    However, the above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a regular basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

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    19.09.2020, 14:36