Dream Finance OÜ ("CoinsPaid
" / "Company
") 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 applied in the Republic of Estonia and worldwide. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.
The purpose of this document is to provide the Company's partners, clients, vendors, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company's AML/CTF compliance regime elements and procedures. By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity.
This document and all underlying policies, processes and procedures are prepared in line with provisions, requirements and recommendations of:
- Money Laundering and Terrorist Financing Prevention Act of Estonia, as amended from time to time ("Act");
- International Sanctions Act of Estonia as amended from time to time; and
- FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Assets Service Providers.
The Company operates from, and under the laws of the Republic of Estonia. Estonia was among the first countries in the world who introduced Anti-money laundering ("AML
") and countering the financing of terrorism ("CTF
") requirements for businesses engaged in exchange of virtual currency for fiat currency and virtual currency custody back in 2017. As a result, each entity rendering named services from or within the territory of Estonia must apply for authorization to the Financial Intelligence Unit of Estonia ("FIUE
Dream Finance OÜ is authorized to provide services of exchanging virtual currency against fiat currency (License No. FVR001183) and virtual currency wallet service (License No. FRK001102) by the FIUE. The licenses can be validated on the official website
of the Ministry of Economic Affairs and Communications of Estonia.
As a regulated business, CoinsPaid is required to comply with the Money Laundering and Terrorist Financing Prevention Act and International Sanctions Act, which require CoinsPaid to identify and verify its clients' identities, conduct ongoing monitoring of their activity, including transaction monitoring, maintain records of clients' activity and related documents for at least five years and report certain transactions to authorities.
The Company understands money laundering
- 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 actions referred to in points (a), (b) and (c).
provides funds for terrorist activity. From legal standpoint it means 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. Terrorist activity has as its main objective to intimidate a population or compel a government to do something. This is done by intentionally killing, seriously harming or endangering a person, causing substantial property damage that is likely to seriously harm people or by seriously interfering with or disrupting essential services, facilities or systems.