Anti-money laundering and know your customer policy (AML&KYC) 

In order comply with AML legislation during provision of services via B2BinPay Software Application we have established a set of rules obligatory for all employees and determining the policy of engagement with any person which uses website and B2Binpay Software Application. Our Compliance Department is intended to ensure that all the operations of the Company are consistent with the international standards to combat money laundering and all the documents provided by the Customer are up-to-date and comply with relevant legal requirements. By using the Website and Software application the Customer makes complete and unconditional acceptance of the policy conditions, agrees with the following rules and undertakes to observe them:  

1. All clients are required to pass KYC verification, namely provide their ID documents and pass liveness check. In circumstances foreseen by legislation, clients are also required to pass video interview; 

2. If you successfully pass the KYC which is associated with relevant tier, you will obtain all benefits foreseen for this Tier. Usually we try to perform KYC procedures as soon as possible, however in separate circumstances it may take several days; 

3. Upon the request of the Company the additional documents and information should be provided by the Customer. Filling of respective KYC questionnaire may also be an obligatory requirement under Company’s sole decision. The Customer agrees with such requirements of the Company and agrees to follow them;

4. The withdrawal of Assets is carried out only to the account that belongs to a person identified as a Customer of the Company. The withdrawal of Assets to third parties is prohibited. Internal transfers between the Company’s customers are also forbidden. 

5. The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about the Customer, as required by applicable law, and the Customer gives the Company its consent to these actions. In order to comply with this paragraph, the Company holds a records about Customer’s transactions during five years at least. 

6. The Customer undertakes to follow the legislation, including international one, aiming to combat illicit trafficking, financial fraud, money laundering and legalization of funds obtained by illegal means. The Customer undertakes to use its best effort to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the Company’s Website, Software Application and Services. 

7. The Customer guarantees the legal origin, legal ownership and the right to use the Assets transferred to its account. 

8. In case of the evidence of suspicious transactions at the Customer’s account, cash replenishments from untrusted sources (darknet, scam, etc.) and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close the Customer’s Account, cancel any payment and to suspend operations on the Accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law, FATF recommendations or by common practice. 

10. The Company has the right to request additional information about the Customer if the method of withdrawal Assets is different from the depositing method. The Company also reserves the right to block the Customer’s Account during the investigation if the Customer refused to provide the additional information requested by the Company.  

11. In the course of investigation the Company has the right to request additional copies of documents confirming the identity of the Customer, as well as copies of bank cards used to replenish the account, payment documents and other documents confirming the lawful possession and legal origin of funds. The Company also has the right to demand the provision of original documents for review in case of any doubts from Company’s side. 

12. The Company does not provide Services to the persons who located at the jurisdictions that are identified by the FATF as high risk and non-cooperative jurisdictions having strategic AML/CFT deficiencies. 

13. The Company doesn’t provide services to citizens and residents of U.S.A.; 

14. The Company’s refuse to perform the operations that from Company’s point of view are considered to be a suspicious, using of preventive measures (such as blocking or closing of a Customer’s Account) is not the reason for civil liability of the Company for failure to fulfill obligations to the Customer. 

15. The Company is not obliged to inform the Customer or other persons about the measures taken to fulfil the AML/CFT legislation. Also the Company is not obliged to inform Customers or other persons about any suspicions, about the reasons of refuse of execution of a Customer’s order, of refuse to open the Account, need for providing Customer’s documents, etc. 

16. This anti-money laundering and know your customer policy is an integral part of the Terms of service for Software application. Non-compliance with this policy can be a ground for termination of any relationships with Customer on Company’s sole discretion.