Introduction
Coinmaster Sp. z o.o, a company incorporated and acting under the Polish laws with the registered address at Piotrkowska str. 116, Lodz, 90-006, Poland, company number 525468892 (“Coinmaster”, “Company”, "We" or "Us").
The Anti-Money Laundering and Know Your Customer Policy, referred to as the "AML Policy," is specifically designed to proactively prevent and mitigate potential risks associated with our involvement in illicit activities, as mandated by both international and local regulations. These regulations require us to establish robust internal procedures and mechanisms aimed at thwarting activities such as money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, as well as corruption and bribery. We are also obligated to promptly address any suspicious activity originating from our users.
It is imperative that all users promptly inform our Compliance Team if they believe or suspect that any actions conflicting with this Policy have occurred or may occur in the future, or if such actions have been solicited by any person.
Customer due diligence (CCD) and Enhanced Due Diligence (EDD)
Customer due diligence is a crucial verification process employed to collect information about our clients, with the aim of identifying and mitigating risks related to activities like money laundering, terrorist financing, and other illegal practices. We conduct a rigorous customer due diligence process to confirm the identity of our clients before establishing a business relationship or processing transactions.
To complete our identity verification procedure, users are required to provide us with credible, independent source documents or data, which may include items such as a national ID, international passport, bank statement, utility bill, and more.
We utilize services from Sum and Substance Limited to conduct screenings of applicants, verifying their inclusion in globally recognized Sanctions and Politically Exposed Persons (PEPs) lists, and scrutinizing warning lists.
When users apply for a Coinmaster Account, they consent to supplying the information and documentation required to meet regulatory requirements. Users are obligated to furnish us with credible, independent source documents for their identification and data confirmation.
We will actively verify the legitimacy of the documents and information submitted by users. We will employ all legally permissible means to cross-verify identification details, and we retain the prerogative to investigate users who are flagged as posing a risk or exhibiting suspicious behavior.
We are mandated to conduct Enhanced Due Diligence when there is a heightened perception of money laundering or terrorist financing risk. This necessitates taking extra measures to gain a deeper understanding of the client's ownership and control, and in certain instances, the origin of the funds involved.
We retain the authority to continuously verify a user's identity, especially when their identification information has been altered or when their activity appears suspicious or unusual for that specific user. Additionally, we have the prerogative to request updated documents from users, even if they have previously undergone identity verification.
We reserve the right to deny the opening of an Account under the following circumstances:
● Users fail to provide the requested information and documents in the correct manner.
● We are unable to undertake and carry out any of the required CDD measures.
● We are unable to establish the identity of Users.
● Subsequent investigation reveals that Users are classified as "prohibited-risk".
● There are suspicions that our Services are being used for illicit activities.
● The risk level of the user or the transaction does not align with our risk assessment criteria.
User's identification information will be collected, stored, shared, and safeguarded in strict adherence to our Privacy Policy and relevant regulations.
The Compliance Team
The Compliance Team, acting with our full authorization, plays a pivotal role in ensuring the effective execution and enforcement of this Policy. Their range of responsibilities covers all aspects related to anti-money laundering and counter-terrorist financing. These responsibilities include, but are not limited to, collecting Users' identification information, developing and keeping up-to-date internal policies and procedures for the creation, review, submission, and retention of all necessary reports and records as required by relevant laws and regulations. The team is also tasked with overseeing transaction monitoring and investigating any significant deviations from regular user activity. The Compliance Team is authorized to collaborate with law enforcement agencies actively involved in the prevention of money laundering, terrorist financing, and other illegal activities.
Monitoring Transactions
In adherence to AML regulations, we conduct daily monitoring of all transactions and maintain the authority to take the following actions when necessary:
● Report suspicious transactions to the appropriate law enforcement authorities.
● Request the User to furnish additional information and documents in the event of transactions raising suspicion.
● Suspend or terminate the User's Account if there is reasonable suspicion of their involvement in illegal activities.
The tasks mentioned above are not exhaustive, and we will continuously monitor user transactions to assess whether they should be marked as suspicious or considered legitimate.
Risk Assessment
User Risk Assessments are conducted to identify the money laundering and terrorist financing risks associated with a particular user.
We will establish a risk profile of each user based on information gathered under this and any other related Policies. By embracing a risk-oriented strategy, we can guarantee that the steps taken to avert or lessen money laundering and terrorist financing align with the risks that have been identified.
Prohibited Activities and Jurisdictions
This website and its content have been produced and disseminated for persons outside of the United Kingdom. The information provided is not directed at or intended for distribution to, or use by, any person or entity located within the UK. The financial products and services mentioned on this website are not eligible for the UK. Cryptoassets are classified as Restricted Mass Market Investments in the UK, meaning that they are high-risk investments and are not suitable for most retail investors.
We strictly enforce a policy that prohibits users from engaging in specific activities and business relationships to ensure compliance with AML, CFT, and Sanctions laws, reducing the risk of our platform being used for financial crime, with prohibited uses including fraud, gambling, money laundering, terrorist financing, and more, and we do not establish business relationships with high-risk jurisdictions or users associated with sanctions, actively cooperating with law enforcement and regulatory authorities to maintain the highest financial integrity standards and prevent illicit activities on our platform.
Record keeping
For the purpose of identification, records of data obtained must be retained for a period of five years after the termination of the business relationship. Similarly, records of all transaction data must be maintained for five years following the conclusion of the business relationship.
Changes to Policy
We reserve the right to make alterations or revisions to any section of this Policy. These changes take effect and are reflected in the "Last updated" section at the top of this Policy.
The User acknowledges that by continuing to use the Website after the updated Policy is published, they accept and consent to the modifications.
Queries
If you have any questions regarding how to adhere to this Policy in a specific case, please feel free to reach out to us via email at [email protected].
