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KYC/AML Policy

Eve Exchange – User KYC & AML policy

Last updated: 01/09/2022

The following is a simplified KYC policy written to inform customers of the steps we take to identify our users and prevent illegal activity on the exchange. By signing up for an EVE Exchange account you agree the following KYC & AML process will be applied. A detailed internal policy is available by contacting [email protected]

Eve Exchange has no tolerance for money laundering, the financing of terrorism or any other form of illicit activity, and is committed to implementing policies, procedures and controls shaped by the best industry practices and the most effective anti-money laundering standards. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.

This document and all underlying policies, processes and procedures are prepared in line with provisions, requirements and recommendations of: FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Assets Service Providers. The company privacy policy offers more detail on how we collect, use and store your data.

The Company understands money laundering as:

The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;

The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity; participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the above actions.

The company understand terrorist funding as:

The provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA.

To comply with regulations the company will:

Request the following information from all clients on sign up via our screening provider Jumio.

  1. ID/Passport – The uploaded document must be readable, of good quality and with all relevant data provided in English alphabet character.
  2. Selfie Image of the applicant holding Passport/ID – the document and photo must be clearly visible.
  3. Proof of address: In some cases we might require a bank statement or utility bill to prove your residency.
  4. Crypto deposits: All deposits made in cryptocurrency the wallet address will be evaluated by chainalysis or similar software. Under certain situations your deposit might be rejected, and your account reviewed.
  5. Source of income or wealth: Under certain situations we might ask the applicant must provide a history of the source of wealth. Source of wealth means the details of the bank account that the investment funds come from.
Customer risk Assessment:

Risk-based customer due diligence calls for the weighing transaction risks and, as a result thereof, qualification of the business relationship in order to decide on the level of the risk. If the risk level of a customer or a person participating in a transaction is low, the Company may apply simplified due diligence measures, but may not skip customer due diligence entirely. If the risk level arising from a customer or a person participating in a transaction is high, enhanced due diligence measures will be applied.

To ensure the prevention of money laundering and terrorist financing, the Company does not process transactions or establish relationships with anonymous or unidentified persons.

The company shall reject relationships If a person fails to provide sufficient information to identify the person or about the purpose of the transactions or if the operations of the person involve a higher risk of money laundering or terrorist financing.

Legislation requires the Company to terminate a continuing contract without the advance notification if the person fails to submit sufficient information for application of customer due diligence measures.

General Obligatory Identification Rules:

Client data will be carefully checked by our KYC/AML processor. If the applicant raises suspicion the company will be unable to open an account.

All documents submitted by clients will be checked and stored for 5 years.

Physical person vs Legal entity:

It is crucial that the type of client is established during the application process, since it will further affect the Know Your Client procedures applied.

Therefore, using the registration form, Eve Exchange will establish whether the prospective client is a physical person or a legal entity.

Physical persons (by default are classified as low risk clients). Legal entities are reviewed in detail. The company shall establish whether the client is the sole beneficial owner of the account, or there are several beneficial owners. This is performed using the registration form, where the client shall specify such parties. Should there be several beneficial owners, all such parties shall be identified. The account shall not be opened until all such beneficial owners are properly identified and verified.

Legal entities

Eve Exchange aims to protect itself from attempts of money-laundering or terrorism financing, hence, being guided by The Wolfsberg Group principles, distinguishes following legal entity types and assigns risk scores accordingly:

• Cash (and cash equivalent) intensive businesses including: money services businesses (remittance houses, exchange houses, casas de cambio, bureaux de change, money transfer agents and bank note traders), casinos, betting and other gambling related activities, or businesses that while not normally cash intensive, generate substantial amounts of cash for certain transactions.
• Unregulated charities and other unregulated “not for profit” organizations (especially those operating on a “cross-border” basis).
• Dealers in high value or precious goods (e.g. jewel, gem and precious metals dealers, art and antique dealers and auction houses, estate agents and real estate brokers).
• Accounts for “gatekeepers” such as accountants, lawyers, or other professionals for their clients, where the identity of the underlying client is not disclosed to the financial institution. Accounts for clients introduced by such gatekeepers may also be higher risk where the financial institution places unreasonable reliance on the gatekeeper for KYC and AML matters.
• Armament manufacturers, dealers and intermediaries.

To establish the type of business, Eve Exchange may request respective corporate documents.

On-going screening

Eve Exchange understands that a one-time client screening is not sufficient to mitigate and control client risks, therefore has also established an on-going screening routine. Depending on the history of relations with the client and the type of match identified, the company will decide whether to continue relationship with the client or not based on internal risk parameters.

Company development

Representatives of Eve Exchange are trying to keep up with the latest technologies and methods of payment and will in every way impede fictitious transactions, money laundering and terrorism financing.

For more information, please email: [email protected]