KYC AML POLICY
The objective of PALCOIN’s KYC (Know Your Customer) policy and procedures is to prevent PALCOIN from being used, intentionally or unintentionally, by criminal elements for money laundering and terrorist financing activities. KYC procedures also enable us to know our clients and their financial dealings better which in turn help us manage the risks prudently.
PALCOIN has established internal KYC procedures to combat money laundering and terrorist financing. The Process serves to build a full client’s KYC Profile.
KYC Process consists of:
Client Due Diligence (CDD) and related activities according to established procedures and client’s risk level.
Identification and verification of the client
Identification and verification of clients involves the collection of specific information about the client, including its ownership and key principals (identification); and gathering evidence from reliable sources that verifies the accuracy of the information collected (verification).
During the implementation of the preventive measures prescribed by the relevant laws, PALCOIN analyses and evaluates the transaction prepared, concluded and/or executed within the framework of the business relationship in order to determine whether it corresponds to the information about the client known to it, the client’s commercial or professional activity and the client’s risk level, and, if necessary – the client’s property, cash and the origin of the convertible virtual asset, as well as ensures that identification data and other information obtained by implementing preventive measures are updated with appropriate periodicity.
Identification of a natural person and his/her representative consists in obtaining the following information:
first name/last name;
citizenship;
date of birth;
place of birth;
ID card and/or another citizenship document number, date of issue, issuing country, issuing body and validity period;
Registered address;
Residing address; and sex.
If client is a branch of a legal entity, shall be additionally obtained the identification data of the client’s head enterprise (organization) and its management and representative authority(ies).
Screening
Screening is conducted as part of the CDD process to identify additional risk factors that may:
elevate a client’s Financial Crime Risk Rating (FCRR) to High (e.g. identification of a Politically Exposed Person (PEP));
prohibit or restrict entering into a business relationship with the client (e.g. the client is subject to international embargoes or sanctions regimes); or
influence the client’s acceptability to Revenue Capital (e.g. material adverse information).
The three types of screening required for a client, including its Ultimate Beneficial Owners (UBO) and key principals, are as follows:
PEP screening: to determine whether the client or individuals connected to the client, meet the definition of PEP;
Sanctions screening: to determine whether the client, or individuals or entities connected to the client are subject to international embargoes or sanctions regimes;
Adverse information screening: to identify potentially adverse information regarding the client, or individuals or entities connected to the client.
The steps to be taken will be different depending on the nature of the high risk factor identified.
Data retention
PALCOIN retains completed KYC Profiles (including the information and documentation contained therein) for 5 (five) years after the date of expiry of the KYC Profile validity period.