AML/KYC Policy — ChangeHero

INTRODUCTION

The purpose of these Guidelines for Anti-Money Laundering (AML), Combating Terrorist Financing (CFT) and Sanctions measures is to ensure that СhangeHero (Company) has internal guidelines to prevent the use of its business for Money Laundering and Terrorist Financing and internal guidelines for implementation of international sanctions.

ChangeHero has a risk-scoring based automated system aimed to spot suspicious activity during operations. A transaction will be put on hold if it is flagged by the system and the user will be asked to pass AML & KYC verification. For security concerns, we are not able to disclose the specific criteria of our system. However, our system has proven to be very effective against any money laundering and scam activities.

We are informing you that ChangeHero reserves the right to assign a Third-party service provider for the sake of carrying out the AML/KYC procedure. Whilst processing information, the service provider abides by our Privacy Policy to ensure the privacy of your personal information.

ChangeHero may share the information received as a result of the AML/KYC procedure with the legal authorities if provided a legitimate official request.

ChangeHero will never go for any agreement with an individual or entity alleged of or directly involved in money laundering or in which the funds sourced from illegal activities.

PRINCIPLES OF COMPANY STRUCTURE AND MANAGEMENT

The organizational structure of the Company must be appropriate to its size and nature, scale and level of complexity of activities and services provided, including associated risks. The Company's chain of command and subordination must be ensured so that all Employees know their place in the organizational structure and know their job responsibilities.

Director and responsible executives are the bearer of a culture of compliance with money laundering and terrorist financing requirements, ensuring that director responsible executives and employees work in an environment where they are fully aware of money laundering and terrorist financing requirements and the obligations associated with those requirements, and relevant risk considerations are appropriately incorporated into the Company's decision-making processes.

The director and responsible executives oversee and are responsible for:

Establishing and maintaining AML/KYC processes, procedures, risks and controls;
Adopting these Guidelines and other internal guidelines and instructions;
Determining the company's AML Measures Manual;
Allocating sufficient resources to ensure effective implementation of the Manual and other relevant documents, and to maintain the organization;
Ensuring that all relevant Employees receive annual AML training.

Employees are responsible for identifying and assessing risks, managing those risks as part of their normal activities, primarily through the application of due diligence measures.

The Company shall take steps to assess the suitability of Employees prior to commencement of employment with appropriate training.

For the above reasons, Employees are required to:

comply with all requirements set forth in the guidelines and other relevant documents;
collect necessary information about the Clients in accordance with their functions and duties;
report information, situations, actions, transactions or attempted transactions that are unusual for any type of service or customer relationship, regardless of the amount, whether or not the transaction has been completed;
undertake the appropriate AML/KYC training required for the employee's position.

THE CRITERIA FOR THE IDENTIFICATION OF SUSPICIOUS/HIGH RISK TRANSACTIONS

The Customer is reluctant to provide information necessary to establish their identity, conceals the identity or provides documents posing doubts on their veracity, authenticity, etc.
Receiving information or documents necessary for the identification from the Customer is difficult: it is difficult to contact the Customer, the Customer does not respond to e-mail messages.
The Customer refuses to provide data on the origin of their funds involved in the transaction.
The Customer uses TOR network services, constantly connecting from IP addresses in different countries.
The Customer has little knowledge of virtual currencies, and cannot explain the ongoing transactions.
Mixer / Tumbler services are used for the transaction.
The customer appears to be a resident of a high-risk region.
The customer uses secure, untraceable cryptocurrencies.

STANDARD DUE DILIGENCE MEASURES

The CDD measures are taken and performed to the extent necessary considering the Customer’s risk profile and other circumstances in the following cases:

upon executing Occasional Transaction(s), where the value of the transaction(s) amounts to 1,000 euros or more.
upon suspicion of Money Laundering or Terrorist Financing.

Measures:

identification of the Customer and verification of the submitted information based on information obtained from a reliable and independent source;
gathering information on whether the Customer is PEP, their family member or a person known to be close associate;
gathering information on whether the Customer is included in any sanction lists such as EU sanction list, UK sanction list, UN sanction list, etc.

Documents required for SDD:

an identity document (ID card, passport, driving license);
photograph.

ENHANCED DUE DILIGENCE MEASURES

In addition to standard due diligence measures, the Company applies enhanced due diligence (EDD) measures in order to manage and mitigate an established risk of Money Laundering and Terrorist Financing in the case where the risk is established to be higher than usual.

The Company always applies EDD measures, when:

the Customer's risk profile indicates high risk level of ML / TF;
upon identification of the Customer or verification of submitted information, there are doubts as to the truthfulness of the submitted data, authenticity of the documents;
in the case of performance of transaction with the PEP, the family member of the PEP or a person known to be the close associate of the PEP;
where a transaction is carried out with persons residing in high-risk countries as identified by FATF, EU Consolidated Sanctions List; the United Nations Consolidated Sanctions List.

Measures:

gather sufficient information about the Customer to determine from publicly available information the reputation of the Customer;
obtain approval from the Director/responsible executives before executing transactions for the Customer;
be satisfied that the Customer has carried out proper Customer due diligence and that they are able to provide the relevant Customer identification data to the Company upon its request.

When applying EDD measures, where transactions are carried out with the PEP, the family member of the PEP or a person known to be the close associate of the PEP, the Company must apply the following measures:

obtain approval from the Director/responsible executives before executing transactions for such Customer;
take adequate measures to establish the source of wealth and source of funds that are involved in the transaction.

PEP must be additionally verified using international search engines (e. g. Google) and the local search engine of the Customer's country of origin, if any, by entering the Customer's name in both Latin and local alphabet with the Customer's date of birth.

At least the following persons are deemed to be PEPs:

the head of the state, the head of the government, a minister, a vice- minister or a deputy minister, a secretary of the state, a chancellor of the parliament, government or a ministry;
a member of the parliament;
a member of the Supreme Court, the Constitutional Court or any other supreme judicial authorities whose decisions are not subject to appeal;
a mayor of the municipality, a head of the municipal administration;
a member of the management body of the supreme institution of state audit or control, or a chair, deputy chair or a member of the board of the central bank;
ambassadors of foreign states, a chargé d’affaires ad interim, the head of the Lithuanian armed forces, commander of the armed forces and units, chief of defense staff or senior officer of foreign armed forces;
a member of the management or supervisory body of a public undertaking, a public limited company or a private limited company, whose shares or part of shares, carrying more than 1/2 of the total votes at the general meeting of shareholders of such companies, are owned by the state;
a member of the management or supervisory body of a municipal undertaking, a public limited company or a private limited company whose shares or part of shares, carrying more than 1/2 of the total votes at the general meeting of shareholders of such companies, are owned by the state, and which are considered as large enterprises in terms of the Law on Financial Statements of Entities of the Republic of Lithuania;
a director, a deputy director or a member of the management or supervisory body of an international intergovernmental organization;
a leader, a deputy leader or a member of the management body of a political party.

The Company shall identify close associates and family members of PEPs only if their connection with PEP is known to the public or if the Company has reason to believe that such a connection exists.

When applying EDD measures where transaction are carried out with persons residing in high-risk countries as identified by FATF, the Company must apply the following measures:

obtaining additional information on the Customer;
obtaining information on the source of funds and source of wealth of the Customer;
obtaining information on the reasons for the intended or performed transactions;
obtaining the approval of the Director/responsible executives for executing the transaction for the Customer;

In any other cases when EDD measures must be applied, the amount of EDD measures and the scope shall be determined by the Employee, who is applying such measures. The following additional and relevant due diligence measures may be followed:

verification of information additionally submitted upon identification of the Customer based on additional documents, data or information originating from a credible and independent source;
gathering additional information on the purpose and nature of the transaction and verifying the submitted information based on additional documents, data or information that originates from a reliable and independent source;
gathering additional information and documents for the purpose of identifying the source and origin of the funds used in a transaction.

MONITORING OF THE CUSTOMER’S ACTIVITY

The Company shall monitor the Customer’s activities or facts that indicate criminal activities, Money Laundering or Terrorist Financing or the relation of which to Money Laundering or Terrorist Financing is probable, incl. complicated, high-value and unusual transactions and transaction patterns.

The Company conducts aforementioned monitoring using available data e.g. previously used Customer’s addresses, known IP addresses, e-mail addresses.

The Company conducts repeated Customer identification in case unusual activities are detected:

the transactions exceed the limits established by the Company;
the transactions do not correspond to the information previously known about the Customer;
the Company wants to or should reasonably consider it necessary to assess whether the transactions correspond to the information previously known about the Customer;
the Company suspects that the transactions indicate criminal activities, Money Laundering or Terrorist Financing.

The Company identifies the source and origin of the funds used in transaction(s) if necessary. The need to identify the source and origin of funds depends on the Customer’s previous activities as well as other known information.

IMPLEMENTATION OF SANCTIONS

Upon the entry into force, modification or termination of sanctions, the Company shall verify whether the Customer is subject to sanctions. If the Company identifies a person who is the subject of sanctions or that a transaction planned or carried out by them violates sanctions, the Company shall refuse to conduct the transaction.

Procedure for identifying the subject of sanctions and the transaction violating sanctions:

The Company shall use at least the following sources (databases) to verify if the Customer is a subject to any sanctions:

EU Consolidated Sanctions List;
The United Nations Consolidated Sanctions List.
Consolidated list of FATF.

In addition to the above sources, the Company may use any other international sanctions lists.

By using ChangeHero's services, you represent and warrant that you have not been included in any economic sanctions list (e.g. Financial Action Task Force on Money Laundering, EU Consolidated Sanctions List; the United Nations Consolidated Sanctions List). ChangeHero reserves the right to select markets, jurisdictions to operate in and may at any time restrict or refuse to provide its services to certain countries and regions.

The Company carries out the above mentioned checks on an ongoing basis. In addition, we reserve the right to conduct enhanced due diligence on all clients in accordance with internationally approved risk-based policies and in accordance with the agreements between the Company and its partners.

REFUSAL TO THE TRANSACTION OR BUSINESS RELATIONSHIP AND THEIR TERMINATION

In the event of any suspicious activity, fraudulent documents or uncooperative customer verification process, the Company reserves the right to refuse a transaction or operation with a customer at any time and to terminate the business relationship if:

The Company suspects money laundering, criminal activity or terrorist financing;
The Company cannot apply CDD measures because the Customer does not provide the relevant data or refuses to provide it, or the data provided does not provide grounds to believe that it is legitimate, authentic, up-to-date, etc.;
Suspicion that a front person is being used to pass the verification;
The Client's transactions have become inappropriate to the Company's risk.

FIAT-TO-CRYPTO/CRYPTO-TO-FIAT PARTNERS

For fiat-to-crypto and crypto-to-fiat procedures, the Users are utilizing the services provided by ChangeHero’s third-party partners. The same partners of ChangeHero may also use our crypto-to-crypto services.

ChangeHero ensures that its fiat-to-crypto and crypto-to-fiat Partners have AML/KYC procedures in place. However, these partners have their own terms and proceedings of AML/KYC, to which the User’s consent has to be provided separately from the ChangeHero’s terms and proceeding of AML/KYC.

CONTACT US

For more information and queries regarding the AML/KYC procedure, please write to us at [email protected].

The information for legal authorities and law enforcement is posted at the For Competent Authorities page of this website. With any relevant inquiry, please contact: [email protected].

ANTI-MONEY LAUNDERING and "KNOW YOUR CUSTOMER" Policies