window.dataLayer = window.dataLayer || []; function gtag(){dataLayer.push(arguments);} gtag('js', new Date()); gtag('config', 'UA-121624253-1');
AML/CTF/KYC Policies2019-02-19T15:19:34+00:00

CoinsPaid – AML/CTF/KYC Policy

Definitions

Money laundering is the movement and disguise of cash or other assets generated from illegal activities through legitimate financial institutions or businesses so as to conceal the source of the funds or make it appear that the source of the funds is, in fact, legitimate.

Money Laundering occurs in three stages:

  1. Placement Stage:

Cryptocurrencies/Tokens and/or Fiat Currencies enter the Financial System, where the assets generated from Criminal Activities are converted into monetary instruments, and deposited/withdrawn or converted via accounts of Financial Institutions.

  1. Layering Stage:

The funds/assets are transferred or moved into other accounts or other Financial Institutions to further hide its Criminal Origin.

  1. Integration Stage:

The funds are reintroduced into the economy and used to purchase legitimate assets or to fund other Criminal Activities or illegitimate Businesses.

Terrorist financing is the process by which terrorists fund their operations in order to perform terrorist acts. Terrorists need financial support to carry out their activities and to achieve their goals. There is little difference between terrorists and other criminals in their abuse of the financial system. While different from money laundering, terrorists often exploit similar weaknesses in the financial system.

To move the funds, terrorists use the formal banking system, informal value-transfer systems, physical transportation of cash, gold and other valuables through smuggling routes and some other techniques.

Know your customer, alternatively known as know your client or simply KYC, is the process of a business verifying the identity of its clients and assessing potential risks of illegal intentions for the business relationship.

United Kingdom and EU – AML and CTF Legal and Regulatory Framework

(i) The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (SI 2017 No. 692)

(ii) The Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2015)

(iii) The Money Laundering Regulations 2017

(iv) The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007).

(v) The European Union’s 4th Anti Money Laundering Directive (the ‘4th AML Directive’) 2015

(vi) ​5th Anti-Money Laundering Directive (Amendments to the 4th Anti-Money Laundering Directive)

FATF list of countries showing a high ML/FT risk for the international financial system

Bahamas, Botswana, Democratic People’s Republic of Korea (DPRK), Ethiopia, Ghana, Iran, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Yemen.

EU list of countries showing a high ML/FT risk for the EU financial system

Afghanistan, Bosnia and Herzegovina, Ethiopia, Guiana, Irak, Iran, Laos, North Korea, Pakistan, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Yemen.

High risk countries (according to World Bank guidelines) when dealing with fiat funds

Afghanistan, Guinea-Bissau, Sierra Leone, Benin, Haiti, Somalia, Burkina Faso, North Korea, South Sudan, Burundi, Liberia, Syrian Arab Republic, Central African Republic, Madagascar, Tajikistan, Chad, Malawi, Tanzania, Comoros, Mali, Togo, Congo, Democratic Republic of Mozambique, Uganda, Eritrea, Nepal, Yemen, Ethiopia, Niger, Zimbabwe, Gambia, Rwanda, Guinea, Senegal, Angola, Indonesia, Papua New Guinea, Bangladesh, Kenya, Philippines, Bhutan, Kiribati, Sao Tome and Principe, Bolivia, Kosovo, Solomon Islands, Cape Verde Kyrgyz Republic Sri Lanka Cambodia Lao People’s Democratic Republic of Cameroon Lesotho Swaziland Congo, Republic of Mauritania Timor-Leste Cote d’Ivoire Micronesia, Tunisia, Djibouti, Moldova, Ukraine, Egypt, Mongolia, Uzbekistan, El Salvador, Morocco, Vanuatu, Georgia, Myanmar, Vietnam, Ghana, Nicaragua, Honduras, Nigeria, Zambia , Pakistan.

Sources used for the identification of PEPs, Criminals, Terrorists and Persons involved in financial crimes

  1. https://www.worldpresidentsdb.com/
  2. http://www.europarl.europa.eu/portal/en
  3. https://www.gov.uk/government/organisations/insolvency-service
  4. https://www.interpol.int/
  5. https://www.un.org/securitycouncil/
  6. http://everypolitician.org/
  7. https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets
  8. www.edisontd.net
  9. https://ec.europa.eu/home-affairs/sites/homeaffairs/files/e- library/documents/policies/borders-and-visas/schengen/docs/handbook-annex_23_part_1_and_2.pdf
  10. https://www.consilium.europa.eu/prado/EN/prado-start-page.html

*CoinsPaid also is using a special Software Tools for User Identity Verification and Identification of PEPs, Criminals, Terrorists and Persons involved in financial crimes.

Description of CoinsPaid Services

CoinsPaid owns and operates an electronic platform that buys and sells bitcoins from third parties and provides customers with the following services:

▪ A B2B Electronic Software Platform for sending and accepting payments in Cryptocurrencies (BTC, BCH, LTC, ETH, ETC, DOGE, DASH, XRP, XMR, ZEC, NEO, DASH, tUSD, ERC20*);

▪ CoinsPaid Wallet via which Cryptocurrencies or cash can be stored, tracked, transferred and managed (without offering any trading facilities);

▪ B2B Exchange/Autoconversion Services where Cryptocurrencies can be converted into Fiat currencies (as for example USD, EUR, GBP, AUD, etc.);

▪ B2B Hedge Services for Cryptocurrencies when a deposited amount in Crypto is fixed to a current rate of the deposited funds in Fiat currency for future withdrawal in cryptocurrency according to the fixed rate of Fiat currency on the date of deposit;

▪ A B2B model for merchants and businesses permitting companies to accept Cryptocurrencies as a payment method for their goods and services via their websites and mobile applications.

CoinsPaid Account Registration and Account Types

A customer can register only one account, thus preventing the setup of multiple accounts.

CoinsPaid offers several Account Types: Merchant, Business, Affiliate (Legal Entities/Individuals).

Also a Customer (Legal Entity or an Individual) can create a personal Wallet to store, track, transfer and manage Cryptocurrencies (without offering any trading facilities).

To register a Merchant Account a Customer should fill in his/her details in the registration form on the CoinsPaid website.

For a Merchant Account: Full Name, E-mail, Company Name

For a Business Account: Full Name, E-mail, Phone Number, Company Name, Business Type, Country

For an Affiliate Account: Full Name, E-mail, Company Name (if applicable)

To open a Wallet: Full Name, E-mail, Phone Number

*Until an Account is not verified for a certain type of CoinsPaid services, a Customer will not be able to use CoinsPaid Services.

KYC Procedure during onboarding for using CoinsPaid Services

In order to become a CoinsPaid customer and make use its services, companies must first register an account and go through specific identity verification and CDD procedure. CoinsPaid makes use of different levels of identity verification dependent upon the type and volume of transactions, which the customers intend to perform via the CoinsPaid Crypto Payment Gateway Platform.

A customer can verify only one account with his/her identity document, thus preventing the setup of multiple accounts. Technical integration will be made only after receiving the Onboarding Application Form, Tech. Details Application Form and all the necessary paperwork according to the Verification Level.

To verify an Account, a Customer must fill the following information in the CoinsPaid Application Form:

  • Full Company Details
  • Full Contact Details
  • Management Company Details
  • Company Bank Details
  • Company/Merchants Websites

As additional check and proof of Company’s or Individual’s intension to open a CoinsPaid Account, a Customer must present additional details, confirming that he or she is not a PEP, not involved in Money Laundering or Terrorism Financing and or any other Criminal Activity, provide Full Business Activity Description, Target Markets, and any other details that may be requested by the CoinsPaid Compliance Department.

Along with the Onboarding Application Form, a Customer must provide a list of necessary documents according to the transaction volumes, currency type and verification levels as follows:

Verification Level Account Type Volume Limits

 Service Type

Cryptocurrency Transactions Cryptocurrency Hedge Service Crypto-Fiat Transactions/Autoconversion CoinsPaid Wallet (Crypto)
BTC (equiv.) BTC (equiv.) BTC (equiv.) EUR (equiv.) BTC (equiv.)
TIER 1 Merchant Day Deposit Unlimited Unlimited Unlimited 10000 Unlimited
Withdrawal 50 25 50 10000 10
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 500 50 250 250000 100
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Business Day Deposit Unlimited Unlimited Unlimited 10000 Unlimited
Withdrawal 75 25 75 10000 10
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 750 50 500 250000 100
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Affiliate Day Deposit Unlimited Unlimited Unlimited 10000 Unlimited
Withdrawal 25 15 25 10000 10
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 250 30 100 100000 100
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Verification Level Account Type Volume Limits Service Type
Cryptocurrency Transactions Cryptocurrency Hedge Service Crypto-Fiat Transactions/Autoconversion CoinsPaid Wallet (Crypto)
BTC (equiv.) BTC (equiv.) BTC (equiv.) EUR (equiv.) BTC (equiv.)
TIER 2 Merchant Day Deposit Unlimited Unlimited Unlimited 50000 Unlimited
Withdrawal 90 25 100 50000 30
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 250 150 500 1000000 100
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Business Day Deposit Unlimited Unlimited Unlimited 50000 Unlimited
Withdrawal 240 50 200 50000 45
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 500 250 500 2500000 150
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Affiliate Day Deposit Unlimited Unlimited Unlimited 25000 Unlimited
Withdrawal 40 15 90 25000 20
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 150 100 250 500000 75
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Verification Level Account Type Volume Limits Service Type
Cryptocurrency Transactions Cryptocurrency Hedge Service Crypto-Fiat Transactions/Autoconversion CoinsPaid Wallet (Crypto)
BTC (equiv.) BTC (equiv.) BTC (equiv.) EUR (equiv.) BTC (equiv.)
TIER 3 Merchant Day Deposit Unlimited Unlimited Unlimited 50000 Unlimited
Withdrawal 150 75 150 50000 100
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 500 250 500 2500000 250
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Business Day Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 250 180 250 50000 250
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 1000 500 750 5000000 500
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Affiliate (*Legal Entity and **Individuals) Day Deposit Unlimited Unlimited Unlimited **10000 / *50000 Unlimited
Withdrawal 100 50 100 **2000 / *50000 50
Storage Unlimited Unlimited Unlimited Unlimited Unlimited
Month Deposit Unlimited Unlimited Unlimited Unlimited Unlimited
Withdrawal 250 150 300 **50000 / *1000000 150
Storage Unlimited Unlimited Unlimited Unlimited Unlimited

*Daily/Monthly Deposit/Withdrawal Limits may differ in each individual case and require Extended Due Diligence and KYC Verification due to local and international regulations as well as technical and bank systems limitations. For more information, please, get in touch with CoinsPaid.

KYC and Due Diligence (Paperwork and Verification)

*List and type of required documents for passing KYC and DD depends on Legislation and may differ in each individual case

**The copies of below specified document must be provided as a color scan copy in high quality

***If any fake document is detected, the incident will be reported to a competent Authority and your Account will be blocked

Account Type

Verification Level

TIER 1 TIER 2 TIER 3
Merchant Crypto Transactions

1. CoinsPaid Agreement (signed by both Parties)

2. Onboarding Application Form

3. Tech. Details Application Form

4. Director(s) ID/Passport/Driver License

5. UBO(s) ID/Passport/Driver License

6. Certifícate of Incorporation

7. Certificate of Goodstanding

8. Memorandum and Articles of Association

Crypto Transactions

1. Shareholders Registry

2. Organization Chart/Structure

3. Full Description of Business Activity

Crypto Transactions

1. Professional Reference Letter

2. Legal Reference Letter

Fiat Transactions

1. Bank Details

2. Bank Reference Letter

Fiat Transactions

1. Director(s) Proof of Address

2. UBO(s) Proof of Address

3. Director(s) Source of Wealth

4. UBO(s) Source of Wealth

5. Bank Statement

Fiat Transactions

1. Director(s) Selfie with ID/Passport

2. UBO(s) Selfie with ID/Passport

3. Company Financial Statement

4. Company AML/CTF/KYC Policy

Business TIER 1 TIER 2 TIER 3
Crypto Transactions

1. CoinsPaid Agreement (signed)

2. Onboarding Application Form

3. Tech. Details Application Form

4. Director(s) ID/Passport/Driver License

5. UBO(s) ID/Passport/Driver License

6. Certifícate of Incorporation

7. Certificate of Goodstanding

8. Memorandum and Articles of Association

9. Full Description of Business Activity

Crypto Transactions

1. Shareholders Registry

2. Organization Chart/Structure

Crypto Transactions

1. Professional Reference Letter

2. Legal Reference Letter

Fiat Transactions

1. Bank Details

2. Bank Reference Letter

Fiat Transactions

1. Director(s) Proof of Address

2. UBO(s) Proof of Address

3. Director(s) Source of Wealth

4. UBO(s) Source of Wealth

5. Bank Statement

6. Transactions Flow

7. Director(s) and UBO(s) CVs

Fiat Transactions

1. Director(s) Selfie with ID/Passport

2. UBO(s) Selfie with ID/Passport

3. Company Financial Statement

4. Company AML/CTF/KYC Policy

5. Video Verification

Affiliate

(*Individual and **Corporate)

TIER 1 TIER 2 TIER 3
Crypto Transactions

1. CoinsPaid Agreement (signed by both Parties) [*/**]

2. Onboarding Application Form [*/**]

3. Tech. Details Application Form [**]

4. Director(s)/Individual ID/Passport/Driver License [*/**]

5. UBO(s)/Individual ID/Passport/Driver License [**]

6. Certifícate of Incorporation [**]

7. Certificate of Goodstanding [**]

8. Memorandum and Articles of Association [**]

Crypto Transactions

1. Shareholders Registry [**]

2. Organization Chart/Structure [**]

3. Full Description of Business Activity [**]

Crypto Transactions

1. Professional Reference Letter [*/**]

2. Legal Reference Letter [*/**]

Fiat Transactions

1. Bank Details [*/**]

2. Bank Reference Letter [*/**]

Fiat Transactions

1. Director(s)/Individual Proof of Address [*/**]

2. UBO(s) Proof of Address [**]

3. Director(s)/Individual Source of Wealth [*/**]

4. UBO(s) Source of Wealth [**]

5. Bank Statement [*/**]

Fiat Transactions

1. Director(s)/Individual Selfie with ID/Passport [*/**]

2. UBO(s) Selfie with ID/Passport [**]

3. Company Financial Statement [**]

4. Company AML/CTF/KYC Policy [**]

CoinsPaid Wallet

(*Individual and **Corporate)

TIER 1 TIER 2 TIER 3
Crypto Transactions

1. CoinsPaid Agreement (signed by both Parties) [*/**]

2. Onboarding Application Form [*/**]

3. Tech. Details Application Form [**]

4. Director(s)/Individual ID/Passport/Driver License [*/**]

5. UBO(s)/Individual ID/Passport/Driver License [**]

6. Certifícate of Incorporation [**]

7. Certificate of Goodstanding [**]

8. Memorandum and Articles of Association [**]

Crypto Transactions

1. Shareholders Registry [**]

2. Organization Chart/Structure [**]

3. Full Description of Business Activity [**]

Crypto Transactions

1. Professional Reference Letter [*/**]

2. Legal Reference Letter [*/**]

Fiat Transactions

1. Bank Details [*/**]

2. Bank Reference Letter [*/**]

Fiat Transactions

1. Director(s)/Individual Proof of Address [*/**]

2. UBO(s) Proof of Address [**]

3. Director(s)/Individual Source of Wealth [*/**]

4. UBO(s) Source of Wealth [**]

5. Bank Statement [*/**]

6. Transactions Flow [**]

7. Director(s) and UBO(s) CVs [**]

Fiat Transactions

1. Director(s)/Individual Selfie with ID/Passport [*/**]

2. UBO(s) Selfie with ID/Passport [**]

3. Company Financial Statement [**]

4. Company AML/CTF/KYC Policy [**]

5. Video Verification [*/**]

Enhanced Due Diligence

*KYC Verification and Due Diligence Procedures can be modified and/or amended at CoinsPaid own Discretion with or without prior notice to comply with United Kingdom Legislation and Local/International Regulations in the field of AML/CTF/KYC/GDPR policies.

CoinsPaid adopts a risk-based approach when carrying out CDD. EDD is applied when dealing with high-risk clients, which are identified either:

  • during the course of carrying out customer due diligence at the on-boarding stage as set out above, or
  • during our on-going monitoring of our clients’ transactions. When a high risk client is identified, we take additional steps to identify and verify potential clients and confirm that their activities and funds are legitimate. In light of the above, we are required to perform additional checks or use independent sources to counteract the heightened money launder or terrorist financing risk.

Record Keeping

CoinsPaid maintains records of all the KYC carried out on all of their customers. Records kept are of a good quality, rendition and clearly legible. CoinsPaid uses a standardized approach to record keeping and ensures that the approach used enables the quick retrieval of records. Data Processing and all the operations corporate details/any confidential information are controlled by DPO (Data Protection Officer). All the data is securely stored in encrypted form.

Data Protection, Compliance & Anti-Money Laundering Officers

CoinsPaid has a duly authorized Data Protection, Compliance & Anti-Money Laundering Officers, whose duty is to ensure the effective implementation and enforcement of the GDPR, KYC and AML/CTF Policies. Furthermore, CoinsPaid also has its’ own internal reporting procedure which clearly states that where an employee has information which could give rise to knowledge or suspicion of money laundering or financing of terrorism, s/he should report the matter to the MLRO or, in his absence, to the designated employee, without delay.

Internal Monitoring of CoinsPaid Employees

CoinsPaid will subject employees to the same AML/CTF procedures as Customer accounts, under the supervision of the MLRO and will also review the AML/CTF compliance.

Confidential Reporting of AML/CTF Non-Compliance

Employees will promptly report to the MLRO and/or competent Authorities any potential violations of CoinsPaid AML/CTF policy compliance by any of current or prospect Customers, unless the violations implicate the MLRO, in which case the employee shall report to CoinsPaid Executives for further investigation.

Final Notice

CoinsPaid may announce and amend its AML/CTF/KYC/GDPR policy from time to time with or without prior notification to comply with United Kingdom Legislation and Local/International Regulations in the field of AML/CTF/KYC/GDPR policies.

This website uses cookies and third party services to improve your user experience. Ok