Crazybutterfly KYC and AML Policy
Anti-Money Laundering
Please note that whilst in some cases virtual currencies can be more advantageous when compared to fiat currencies, it is important for each business to fully understand the risks involved before deciding to take on an exposure to virtual currencies.
Virtual currency be considered as a relatively high- risk asset for the following reasons –as a company that operates in a wide variety of industries and in the relatively new virtual currency fields, Crazybutterfly s.r.o recognises that it can be target of would-be money launderers.
Crazybutterfly's Mission and Approach
Crazybutterfly has established an AML Program to help protect our clients and our business from the risks of money laundering, terrorist financing and other financial crimes.
This includes:
⦁ Risk based approach: This has been designated by Crazybutterfly's senior management as the responsible body for overseeing company’s AML Program, including appraising senior management of AML compliance initiatives, any significant compliance deficiencies, and the reporting of suspicious activity;
⦁ Governance controls: This control framework governs the overall program, including AML policies, processes, training and testing.
AML Program Execution
Crazybutterfly 's risk management framework – including the AML Program – is based on the following:
⦁ First Level of Defence (Business) - Each of Crazybutterfly 's employees owns and manages the risks, including compliance risks, inherent in or arising from the business and is responsible for having controls in place to mitigate key risks and promoting a culture of compliance and control.
⦁ Second Level of Defense (Legal, Compliance, and Finnace) - Compliance, Finance, Legal and Risk, set standards according to which Crazybutterfly and its business is expected to manage and oversee risks, including compliance with applicable laws, regulatory requirements, policies, procedures, and standards of ethical conduct.
Standard procedure for customer identification and verification (on-boarding customers)
The Crazybutterfy applies the following due diligence measures (CDD):
1) identification of a customer or a person participating in an occasional transaction and verification of the submitted information based on information obtained from a reliable and independent source, including using means of electronic identification and of trust services for electronic transactions;
2) identification and verification of a representative of a customer or person participating in an occasional transaction and their right of representation;
3) identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the obliged entity to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer or of the person participating in an occasional transaction;
4) understanding of business relationships, an occasional transaction or operation and, where relevant, gathering information thereon;
5) gathering information on whether a person is a politically exposed person, their family member or a person known to be their close associate;
6) monitoring of a business relationship.
The relevant employee must identify all customers who want to use our Company's services on the basis of an identity document and shall record the identification and transaction data regardless of whether the customer is a regular customer or not.
A person must be identified:
⦁ prior to establishing a business relationship;
⦁ upon suspicious customer behaviour;
⦁ upon verification of information or in the case of doubts as to the sufficiency or truthfulness of the documents or data gathered beforehand while updating relevant data;
In identifying a person, the relevant employee is obliged to check the validity of the identity document, make sure the person matches the information on the document and check the age of the person. If in doubt about the identity of the person, the relevant employee is obliged to request additional Information about the person. Upon sending a document that does not match the person or is invalid, the relevant employee must refuse the customer registration and notify the Compliance Officer.
The relevant employee verifies the correctness of the customer data, using information originating from a credible and independent source for that purpose, where the identified person has a valid document. The person is identified and the person's identity is verified on the basis of the document or using means of electronic identification and trust services for electronic transactions, and the validity of the document appears from the document, or can be identified using means of electronic identification and trust services for electronic transactions, no additional details on the document need to be retained.
The relevant employee may ask additional information about the customer in case of any suspicion about the customer's identity information or the customer's behaviour. Such additional information asked should be relevant to the raised risks which, when obtained, may prove that the risks are in fact explainable.
No business relationship will be established with the client who cannot provide the requested documents or does not comply with company AML/KYC requirements. The company's internal procedural rules describe a more detailed customer onboarding procedures and applicable risk assessment matrix
Finally
Crazybutterfly is fully committed to remaining vigilant to prevent the use of our products and services by those who seek to abuse them. We continually seek to combat money laundering and terrorist financing through the prevention, detection and reporting of unusual or suspicious behavior. We actively work to prevent terrorist organizations from accessing our financial services, readily assist regulators and law enforcement agencies in their efforts, and promptly respond to inquiries.
We also continually evaluate the strength of our existing policies, procedures and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure that they are well versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering and other financial crimes. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering and terrorist financing, and implement appropriate processes to mitigate, and ultimately alleviate, such risks.
28.09.2022