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AML & KYC Policy

1. This policy is the Anti Money Laundering (AML) and Know Your Customer (KYC) Policy of SRL
2. Money laundering is the process of transforming the profits of crime and corruption into ostensibly "legitimate" assets. In a number of legal and regulatory systems, however, the term money laundering has become conflated with other forms of financial and business crime, and is sometimes used more generally to include misuse of the financial system (involving things such as securities, digital currencies, credit cards, and traditional currency), including terrorism financing and evasion of international sanctions. Most anti-money laundering laws openly conflate money laundering (which is concerned with source of funds) with terrorism financing (which is concerned with destination of funds) when regulating the financial system. (Wikipedia).
3. Although SRL is currently unregulated and do not fall within the scope of the AML obligations in Romania, we have implemented systems and procedures to prevent money laundering and not be used by criminals to launder proceeds of crime of finance terrorism. The purpose of this AML is to ensure not only that SRL are compliant with current legislation and requirements, but also to show that they take any form of illegitimate use of their services seriously.
4. If SRL suspect any customer is abusing their services for the purposes of money laundering, SRL reserve the right to suspend any transactions pending the outcome of an internal investigation. SRL reserve the right to report any suspicious activities to the police or relevant authorities without the customer's knowledge.
5. In accordance with the current industry best practice guidelines, SRL:
- Have established a risk based approach towards assessing and managing the money laundering risks to the business
- Have established and maintain risk based customer due diligence and obtain identification and proof of address in accordance with KYC (know your customer) which includes enhanced due diligence checks for customers which may present a higher risk, this will be determined at the sole discretion of SRL
- Have established and maintain risk based systems and procedures to monitor ongoing customer activity
- Have procedure for flagging and (if needed) reporting suspicious activity
- Pay special attention to all complex, unusually large transactions
- Employ proper care in the hiring of new staff
- Assist law agencies and authorities to trace and seize the proceed of criminal activities
6. SRL prohibits anonymous accounts and accounts in obviously fictitious names. SRL undertakes customer due diligence measures when establishing business relations or performing transactions, when there is a suspicion of money laundering or terrorist financing, or when it has doubts about previously obtained customer information. If SRL is unable to verify the identity of a customer, then it will not establish business relations or perform transactions with this customer, and it will consider reporting to competent authorities.
7. As part of our AML policy, we ensure that any customer agreeing to use our services, is also agreeing - if it is requested by SRL - to provide us with identification documentation, including but not limited to the high resolution color scan of all sides of the following Personal Identity Documents and/or Proof of Address Documents:
1) Personal Identity Documents:
- Current valid full EU or non EU Passport
- Current valid National ID card
- Current valid Driving License
2) Proof of Address Documents:
- Recent Utility Bill, Gas, Electricity, Water, Telephone (Not mobile phones)
- Bank Statement

We reserve the right to require additional information at any time to verify the customer's identification and any further information that may be required to satisfy the Money Laundering Regulations.
In order to have adequate due diligence checks in place SRL set up the following step by step verification process:

1) Verified e-mail address
2) Full Name
3) Verified mobile phone number
4) High resolution color scan of all sides of Government issued Photo ID
5) Bank account number under customer name
6) High resolution color scan of all sides of Proof of Residence
7) Photo of customer holding his / her IDs and a handwritten paper showing a text that SRL provide OR Face-to-face meeting with one of SRL designated employees for due diligence.
8. SRL includes required and accurate originator and beneficiary information on bank transfers, and monitors bank transfers to detect those lacking required and accurate originator or beneficiary information. SRL does not conduct business with sanctioned persons and entities. SRL may rely on third parties to perform elements of the customer due diligence measures (like SEPA bank transfers).
9. SRL maintains transaction records and customer due diligence information for at least 7 years. SRL makes this information available to competent authorities upon request.
10. SRL takes reasonable measures to determine whether a customer is a politically exposed person and applies additional measures to establish business relations or perform transactions.
11. SRL may impose limits on the amount of cryptocurrency that customer may buy or sell in a given day / month. SRL reserves the right to change the amount of cryptocurrency that customer may buy from, or sell to, SRL, or through any of its Services as we deem necessary or appropriate from time to time.
12. SRL policy is to comply with applicable laws and regulations regarding AML and identity verification (KYC), and to detect and prevent the use of its service to launder money, commit fraud or other crimes. We are committed to protecting the privacy of our users, but we will not allow anybody to use our services to launder money, commit fraud, or other crimes or illegal conducts.
13. SRL reserve the right to change this Policy any time (or to comply with relevant laws and regulations) by amending this page. Please check this page from time to time to take notice of any changes we have made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.

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Termenii si Conditiile de Utilizare | Politica AML & KYC | Politica de Privatiune

Copyright ⓒ 2017 SRL
440038, Satu Mare, Romania
EUID: ROONRC.J30/907/2017
VAT: 38011198
Capital Social: 50,000 RON