KYC & AML Policy

It is the policy of EUROTOKEN OÜ (Harju maakond, Tallinn, Kesklinna linnaosa, Roosikrantsi tn 2-K468, 10119; registration number: 14454785),  a  private limited company  established  under  the  the  Estonia laws, which is holding an Estonian virtual asset service provider (hereinafter “VASP”) licence and which  is  the  operator  of  the  Internet platform, hereinafter referred to as "Company", approved for: to prohibit and actively prevent money laundering and any activity that facilitates money laundering  or  the  funding  of  terrorist  or  criminal  activities  by  complying  with  all applicable  requirements  under  the  Money  Laundering  and  Terrorism  Prevention  Act, Anti-Money  Laundering  and  Combating  the  Financing  of  Terrorism  Guidelines,  FATF recommendations and its implementing regulations; and to ensure that the most appropriate action is taken by Company to mitigate the risks associated with financial crime.

In all cases not specified in this policy, Company follows the guidelines set by Directive  (EU)  No  2015/849,  Directive  (EU)  No  2018/843,  as well  as  the  Estonian  Money Laundering and Terrorist Financing Prevention Act of 26.10.2017. Any  breaches  of  our  procedures  relating  to  the  prevention  of  money  laundering  and  the combating  of  terrorist  financing  will  be  dealt  with  severely  and  may  be  treated  as  gross misconduct. This abstract of the Company's Anti-Money Laundering and Know Your Customer (hereinafter “KYC & AML”) policy describes shortly the applicable customer due diligence measures and other related procedures.

As a fundamental principle deriving from the Estonian Money Laundering and Terrorist Financing Prevention Act, all Estonian VASPs are required to apply for a license and to identify each and every customer before providing any services irrespective of the value of the first transaction.

Consequently, the Company shall apply at least the following due diligence measures to ALL the customers:

  1. identification of a customer and verification of the submitted information;
  2. identification and verification of a customer´s representative, if applicable;
  3. identification of the beneficial owner, if applicable;
  4. understanding the prospects of the client relationship;
  5. validating the information regarding involved crypto wallets;
  6. verifying the customer´s politically exposed person (a.k.a. PEP) status;
  7. screening a customer against international sanctions;
  8. monitoring of the client relationship as a whole.

The application of the above measures may take various forms and be applied at different times. For example, a customer may be asked to provide a passport copy and a selfie first and a utility bill later to verify its identity. Customer may be asked about planned transactions frequency and expected amounts per month to understand the nature of the client relationship. Company shall determine customer´s PEP status and shall carry out sanctions checks from time to time by asking the customer or by using an automated recurring solution. Last but not least, the Company applies continuous monitoring over customer's information and all the transactions to discover any inconsistencies, suspicions or fraud. You understand and agree that submission of this data will not guarantee the establishment of the relationship and further provision of Services to You by ATAIX.

The Company is required to determine the risks associated with each customer. The level of risk is assessed by identification and analysis of different risk factors (e.g. country of residence, quality of submitted information, pattern of transactions, answers to inquiries). If a customer's risk is high, the Company shall not establish a business relationship with a new customer or it shall not provide the relevant service to an existing customer, as applicable, until the risk has been mitigated to a reasonable level. The Company applies enhanced due diligence measures for that purpose. If a customer's risk remains high even after the application of enhanced due diligence measures, a new customer will not be on-boarded or an existing customer will be off-boarded, as applicable.

The Company may apply the following enhanced due diligence measures to the customer with a high-risk factor:

  1. conducting video verification (interview);
  2. gathering additional information on the identity of the customer;
  3. gathering additional information on the purpose and nature of the client relationship;
  4. gathering additional information and documents regarding the actual execution of transactions made in the business relationship;
  5. gathering additional information and documents for the purpose of identifying the source and origin of the funds used in a transaction made in the business relationship;
  6. asking to make a payment related to a transaction via an account that has been opened in the name of the customer in a credit institution registered or having its place of business in a country of the European Economic Area or in a country where requirements equal to those of Directive (EU) 2015/849 are in force;
  7. the application of customer due diligence measures face-to-face;
  8. verification of information submitted based on additional documents, data or information originating from a credible and independent external source.

The information provided by the customer must be correct and up-to-date at all times. The Company has the right to request additional information and/or updated documents from the customer at any time. If the customer refuses to provide the relevant information or documents for any reason, the Company is obliged to refuse on-boarding a new customer or to off-board an existing customer, as applicable.

The Company is required to report to the Estonian Financial Intelligence Unit (FIU) about suspicious transactions and customers, including customers that refuse to submit comprehensive information during an on-boarding process. Please note that the Company is strictly prohibited by the law to provide any information to the customers with respect to such reports.

The Company registers and retains the data of all potential, current and old customers and their transactions for at least five years, in correspondence with the Company's Privacy Policy and the Estonian Money Laundering and Terrorist Financing Prevention Act.

In order to comply with international AML regulations, we are currently unable to provide services to residents and companies from some countries. The list of non-serviced countries is subject to change. Current list of countries: Afghanistan, Albania, Algeria, Bahamas, Bahrein, Barbados, Bolivia, Bosnia and Herzegovina, Botswana, Cambodia, Central African Republic, Crimea, Cuba, DR Congo, Democratic People's Republic of Korea, Ecuador, Ethiopia, Guyana, Ghana, Iceland, Iran, Iraq, Japan, Jamaica, Kosovo, Kuwait, Lao DPR, Lebanon, Libya, Mali, Mauritius, Mongolia, Myanmar, Nepal, Nicaragua, Pakistan, Palestine, Panama, People's Republic of China, Qatar, Saudi Arabia, Somalia, South Sudan, Sri Lanka, State of Palestine, Sudan, Syria, Trinidad and Tobago, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe, United States of America.

The Company reserves the right to change the original KYC & AML policy and this abstract from time to time. By continuing the use of the Company's services after the changes take effect, the customer agrees to be bound by the changed policy.

If you visit other third-party platforms or our partner’s websites, apps via the links on ATAIX, you should agree with and abide by their separate and independent KYC & AML policies. We are not responsible for the content or the activities therein.

This KYC & AML Policy applies to all platforms, websites, and departments of ATAIX. If you visit any link to any ATAIX friendly or partners’ platforms, you should agree with and abide by the separate and independent KYC & AML policies of such platforms. If the KYC & AML policy of any platform conflicts with this KYC & AML Policy, the KYC & AML policy of such platform shall prevail.

Our aim is to provide compliant, secure, safe and licensed crypto services to everybody. We are not able to do it without your valuable input and close collaboration. If you have any questions regarding our KYC & AML policy, please do not hesitate to contact our customer support!