KYC & AML Policy

INTRODUCTION

We at Instacoins are committed to the highest standards of AML in order to protect against the use of our services for the purpose of money laundering. The requirements outlined in this Policy are the minimum prerequisites based on legal and regulatory demands. These requirements are intended to prevent Instacoins, our staff, partners and clients from being taken advantage of for money laundering, terrorist funding or any other monetary crime.

We set out to accomplish this by doing the following:

-Carrying out regular risk assessments to establish our risk profile
-Developing strict AML policies and procedures
-Employing internal controls that are intended to reduce the risk of money laundering
-Carrying out Know Your Customer (“KYC”) procedures on every user
-Assigning a Compliance Officer with complete responsibility for our AML System
-Having all employees complete AML training

CUSTOMER IDENTIFICATION

We have put into practice a risk-based strategy as part of our due diligence procedures in line with the present-day UK AML/KYC regulations. This report regulates how we handle the enrollment of customers’ accounts, what details are collected and how information is verified.

Instacoins identifies each client by acquiring a wide range of information about him/her. Identity verification consists of confirming some of this information by comparing it to documents or data acquired from a trusted source which is independent of the client.

No less than the following details must be received from each client for identification purposes: name and surname; personal identity number (if applicable); date of birth; color photograph on a government-issued document which confirms client identity, residential address, personal identification document number and the expiration date of the identification document.

Once a client is successfully identified and their identity is verified, Instacoins must carry out a certain level of due diligence based upon a risk-based strategy. For some client relationships, established by the company to present a low level of risk, simplified due diligence may be applied. In higher risk circumstances, enhanced due diligence measures must be employed on a need-be basis.

KYC OFFICER

Instacoins has selected a member of senior management to act as Chief KYC Compliance Officer. This helps to ensure that communication between us and governing authorities is clear and efficient. The primary role of said officer is to establish a platform where any staff member possesses satisfactory skills and knowledge to alert us of suspicions of money laundering or terrorist funding. Staff members also have clear instructions to report their suspicions as soon as possible.

PURCHASE TRACKING

Instacoins maintains an ongoing live purchase monitoring process for the intent of revealing suspicious activity. We do not rely entirely on a set of predefined rules, but instead use a risk-based strategy. The strategy makes use of mathematical and analytic techniques to recognize patterns of unusual and suspicious actions by constructing user profiles on each individual client and assessing their financial actions against anticipated and/or peer group norms. This is done by making use of various data statistics tools for flagging anything that is categorized as not normal.

Instacoins reserves the right to decline to process a purchase request at any time. Especially when we think that a purchase is linked in any way to money laundering or any other form of criminal activity. In accordance with local laws, we are not required to inform the client that suspect actions have been reported to authorities.

REPORTING

Instacoins has founded a method in which its staff reports to their direct managers to provide assessment for the reasoning of the additional disclosure. All internal accounts are recorded in an appropriate manner, with the nominated KYC officer maintaining a safeguarded suspicious report register. The nominated officer evaluates any risk that is presented by a transaction or activity. In instances where there are affiliated accounts, an evaluation of such relationships will be done. If any internal review has suggested enough grounds to know or suspect that criminal activity has or may have taken place, an external report will be submitted in a timely manner.

RECORD KEEPING

Instacoins keeps records of all customers’ identity, along with the supporting evidence of identity verification (including original and any updated records). Also kept are business relationship information and details of any transactions. As per regulation demands, we preserve records for a period of at least five years from the date that a business relationship comes to an end or from the date of the last financial transaction.

TRAINING

We ensure that all staff members are aware of our AML program and ask that training is given to all employees (new and current) before conducting business.

This training must include:

-Understanding and spotting money laundering and/or fraud
-Verifying client identification
-Identifying suspect activity
-Reporting requirements related to suspect transactions

Additional training will be provided to all staff based on, but not restricted to, modifications to government regulations, Instacoins AML Compliance Program requirements and policies, or in the occurrence of a performance problem related to an AML incident.

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