1. Introduction
The Anti-Money Laundering and ‘Know Your Client’ Policy (“AML / KYC Policy”) is designed to prevent and mitigate the possible risks of 1654 Exchange being involved in any illegal activity.
2. The purpose of internal regulation
The Service adheres to anti-money laundering and counter-terrorist financing (AML) practices and measures. The purpose of these measures is to demonstrate that 1654 Exchange takes seriously any attempt to use its service for illegal purposes.
3. Caution
The 1654 Exchange service warns users against trying to use the service for money laundering, terrorism financing, fraud of any kind, as well as using the service to purchase illicit goods and services.
Service 1654 Exchange, its administration, employees and domain owners are not responsible for misuse of the service by third parties, for actions of intruders and possible damage related to the use of the service.
4. claims
In order to prevent transactions of illegal nature, the 1654 Exchange service stipulates certain requirements for all Requests created by the User:
4.1 The sender and recipient of a Payment Order must be the same person. Transfers in favour of third parties using the Service are strictly prohibited.
4.2 All the contact details stated in the User’s Order as well as any other personal data must be truthful and correct.
4.3 Orders created by the User using anonymous proxy-servers, VPN, Tor or any other anonymous Internet connections are strictly prohibited.
5. Verification Procedures
One of the international standards for preventing illegal activities is due diligence of customers (hereinafter referred to as Verification). To this end, 1654 Exchange implements its own verification procedures in strict anti-money laundering standards and Know Your Client procedure.
5.1 Service 1654 Exchange may require the User to provide the Service with reliable, independent source documents, data or information (e.g. national ID card, international passport, bank statement). For such purposes, Service 1654 Exchange reserves the right to collect User identification information for purposes of compliance with AML/KYC Policy.
5.2 Service 1654 Exchange will take steps to verify the authenticity of documents and information provided by Users. All legal methods to double check identification information will be used, and the Service reserves the right to investigate cases of certain Users whose identities have been identified as dangerous or suspicious.
5.3 The 1654 Exchange Service reserves the right to verify the identity of a User on an ongoing basis, especially when their identification information has been changed or their activity appears suspicious (unusual for a particular User). Furthermore, Service 1654 Exchange reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.
5.4 User identification information will be collected, stored, shared and protected strictly in accordance with 1654 Exchange Privacy Policy and relevant regulations.
5.5 After verifying the User’s identity, the 1654 Exchange Service may refuse to provide services to the User in a situation where the Service services are used to conduct illegal activities.
5.6 Users who intend to use payment cards for the purpose of consuming services must go through card verification in accordance with the instructions available on the 1654 Exchange website.
5.7 Service 1654 Exchange has regulatory requirements to verify the source of funds or cryptocurrency to know that the sources of funds that Users use to trade are legal.
6. Responsible Officer
The AML Compliance Officer is the person duly authorised by the 1654 Exchange Service whose duty it is to ensure the effective implementation and enforcement of AML/KYC policies.
6.1 The duty of such officer is to oversee all aspects of 1654 Exchange’s anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods:
– collecting user identification information;
– establishing and updating internal policies and procedures for completing, reviewing, submitting and maintaining all reports and records required under applicable laws and regulations;
– monitoring transactions and investigating any significant deviations from normal operations;
– implementing a records management systеm to properly store and retrieve documents, files, forms and logs;
– updating the risk assessment on a regular basis;
– Providing law enforcement authorities with the information required under applicable laws and regulations.
6.2 The AML Compliance Officer is authorised to liaise with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illicit activities.
7. systеm functions
Service 1654 Exchange performs many compliance-related tasks, including data collection, filtering, record keeping, investigation management and reporting.
systеm functions inсlude:
– Checking Users daily for the existence of recognised blacklists (e.g. OFAC), aggregating transmissions across multiple data points, placing Users on watch and denial lists, opening cases for investigation where appropriate, sending internal messages and completing mandatory reports where applicable;
– case and document management.
8. Behavior Analysis
The 1654 Exchange Service verifies Users not only by verifying their identity, but more importantly by analysing their transaction behaviour. The Service therefore relies on data analysis as a risk assessment and suspicion detection tool.
9. Risk assessments
1654 Exchange, in compliance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, the Service ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified.
10. Execution of customer checks
If the 1654 Exchange administration has reasonable suspicion that the user is attempting to use the Service for money laundering or any other illegal transaction, the administration has the right to
10.1. suspend the execution of the User’s exchange transaction;
10.2. request identification documents from the User;
10.3. request any additional information and documents from the User in case of suspicious transactions;
10.4. ensure that reports of suspicious transactions are given to proper law enforcement authorities via the AML compliance officer.
11. Privacy
Service 1654 Exchange guarantees client confidentiality in accordance with the service’s privacy policy.
11.1 Service 1654 Exchange and its employees are committed to maintaining the confidentiality of any facts revealed in connection with any questionable transaction. This obligation also applies to the users of the Service and to third parties to whom information on the transaction was transmitted.
11.2 The obligation of confidentiality imposed on the employees of the Service 1654 Exchange, shall survive the termination of their employment or any other contractual relationship with the Service, as well as the transfer of such employees to another workplace. Disclosure of such information to governmental, law enforcement agencies and other entities in cases defined by law does not constitute a breach of the obligation of confidentiality.
11.3 The obligation of confidentiality, provided that the use of the information disclosed is limited to preventing the legitimisation of the proceeds of crime and terrorist financing, may not apply to disclosures between financial institutions forming a consolidated group that cooperates with Service 1654 Exchange.
12. Conclusion
In view of the above, Service 1654 Exchange assumes no legal liability for its use for money laundering, terrorist financing, or the purchase of prohibited items or services, but undertakes to take all possible and available actions to prevent attempts to use the Service for money laundering, terrorist financing, or the purchase of prohibited items or services.
