Important Notice

Dream Finance UAB (Lithuania) has temporarily suspended the provision of all crypto-asset related services, including onboarding of new clients, execution of transactions, and conclusion of new agreements.

During this period, the company does not offer, market, or provide any services described on this website. Any product descriptions or references are provided for informational and historical purposes only and shall not be interpreted as an offer, solicitation, or availability of services.
This website is maintained solely to provide mandatory legal information, regulatory disclosures, and contact details for former clients, counterparties, and competent authorities.

For inquiries related to existing contractual obligations, outstanding matters, or regulatory questions, please contact us at: [email protected].

Last Update: September 22, 2022

AML Policy

Dream Finance, UAB (“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 Lithuania 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 Lithuania, as amended from time to time (“Act“);
  • Regulation (EU) 2024/1624 and Directive (EU) 2024/1640 (AMLD 6);
  • 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 Lithuania. Dream Finance, UAB established in the Republic of Lithuania on March 9, 2022, with the registration number 306036821.

As a regulated business, CoinsPaid is required to comply with the AML CTF and Sanctions regulations, 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 eight years and report certain transactions to authorities.

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 actions referred above.

Terrorist financing 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 Title 3 of Directive (EU) 2017/541 of the European Parliament and of the Council. 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.

Risk-Based Approach and Risk Assessment

CoinsPaid will perform a risk-based due diligence and collect information and documentation on each prospective client in order to assess the risk profile associated. The Company’s employees will exercise care, due diligence and good judgement in determining the overall character and nature of all clients. CoinsPaid conducts its business in accordance with the highest ethical standards and will not enter into business relationships with individuals or entities that may adversely affect Company’s reputation and compromise the virtual currency industry.

For the purpose of identification, assessment and analysis of risks of money laundering and terrorist financing related to its activities, the Company prepares a risk assessment, taking account of at least the following categories:

  • Customer risk;
  • Geographical Risk;
  • Product Risk;
  • Delivery Channel;
  • Behavioral or Transactional Risk.

After the risk is assessed and attributed to a particular customer, depending on the degree of risk, it should be revised periodically upon knowledge of the customer and its activity.

Money Laundering Reporting Officer (MLRO)

The management board of the Company shall appoint an MLRO, who acts as a contact person of the Financial Crime Investigation Service (FCIS) and performs AML/CTF duties and obligations of the Company. MLRO reports directly to the management board and has the competence, means and access to relevant information across all the structural units of the Company.

Only a person who has the education, professional suitability, the abilities, personal qualities, experience and impeccable reputation required for performance of the duties listed below may be appointed as a MLRO. The appointment of a MLRO in the Company is reported to the FCIS.

The duties of a MLRO include, inter alia:

  • organisation of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the Company;
  • reporting to the FCIS in the event of suspicion of money laundering or terrorist financing;
  • periodic submission of written statements on compliance with the requirements arising from the Act to the management board of the Company;
  • performance of other duties and obligations related to compliance with the requirements of the Act.

Rules of Procedure and Internal Control Rules

The Company has developed and implemented rules of procedure that allow for effective mitigation and management of risks relating to money laundering and terrorist financing, which are identified in the risk assessment performed in accordance with the Company’s risk-based approach described above.

Each employee of the Company should strictly adhere to rules of procedure set forth herein.

The rules of procedure consist of the following:

  • a procedure for the application of due diligence measures regarding a customer, including a procedure for the application of  enhanced due diligence measures;
  • a model for identification and management of risks relating to a customer and its activities and the determination of the customer’s risk profile;
  • the methodology and instructions where the Company has a suspicion of money laundering and terrorist financing or an unusual transaction or circumstance is involved as well as instructions for performing the reporting obligation;
  • the procedure for data retention and making data available;
  • instructions for effectively identifying whether a person is a politically exposed person or a local politically exposed person subject to international sanctions.

The Company applies the following due diligence measures:

  • identification of a customer and verification of the submitted information based on information obtained from a reliable and independent source, including using means of electronic identification and of trust services for electronic transactions;
  • identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer;
  • understanding of business relationships, and, where relevant, gathering information thereon;
  • gathering information on whether a person is a politically exposed person, their family member or a person known to be close associate;
  • monitoring of a business relationship.

Enhanced Due Diligence

The Company applies enhanced due diligence (“EDD“) measures in order to adequately manage and mitigate a higher-than-usual risk of money laundering and terrorist financing.

EDD measures are applied always when:

  • upon identification of a person or verification of submitted information, there are doubts as to the truthfulness of the submitted data, authenticity of the documents or identification of the beneficial owner;
  • the customer is a politically exposed person or their family member or a close associate is a politically exposed person;
  • the customer is incorporated in a EU high-risk third country or their place of residence is in a EU high-risk third country;
  • the customer is incorporated in a FATF high-risk country or their place of residence is in a FATF high-risk country;
  • the customer is from such a country or territory that, according to credible sources such as mutual evaluations, reports or published follow-up reports, has not established effective AML/CTF systems that are in accordance with the recommendations of the Financial Action Task Force, or that is considered a low tax rate territory.

The Company applies EDD measures also where a risk assessment prepared on the basis of these rules identifies that, in the case of the economic or professional activity, field or factors, the risk of money laundering or terrorist financing is high.

PEP Definition and Screening

Politically Exposed Persons (“PEP“) (as well as their families and persons known to be close associates, as described below) are required to be subject to enhanced scrutiny by reporting entities. This is because international standards issued by the Financial Action Task Force recognize that a PEP may be in a position to abuse their public office for private gain and a PEP may use the financial system to launder the proceeds of this abuse of office.

PEP means a natural person who is or who has been entrusted with prominent public functions including:

  • Head of state, head of government, minister, vice-minister or deputy minister, state secretary, or the chancellor of the parliament, government, or a ministry.
  • Member of parliament.
  • Judge of the highest courts, constitutional courts, or other supreme judicial bodies whose decisions cannot be appealed.
  • Mayor of a municipality or director of a municipal administration.
  • Member of the management body of the highest state audit or control institution, or the chair, deputy chair, or board member of the central bank.
  • Ambassador, chargé d’affaires, commander of the Lithuanian Armed Forces, commanders of military branches and units, Chief of the Defence Staff, or a high-ranking officer of a foreign country’s armed forces.
  • Member of the management or supervisory body of a state-owned company or a company where the state owns more than half of the voting shares.
  • Member of the management or supervisory body of a municipal company or a company where the municipality owns more than half of the voting shares, provided the company is considered a large enterprise under Lithuanian law.
  • Head, deputy head, or member of the management or supervisory body of an international intergovernmental organization.
  • Leader of a political party, their deputy, or a member of its management body.

Close associate means a natural person who is a member of the same legal entity or organization (even if it has no legal status) as the person holding (or previously holding) the important public function listed in Article 18, or who has other business relationships with that person. A natural person who is the sole beneficial owner of a legal entity or organization (with or without legal status) that was created or is operating de facto for the financial or other personal benefit of the person holding (or previously holding) the important public function listed in Article 18.

Close family members means a spouse, registered partner (cohabiting partner), parents, brothers, sisters, children, and the spouses or partners of those children.

Sanctions Screening

Dealing with persons against which imposed international sanctions poses a great risk to the Company, its directors, officers and owners.

The Company will perform sanction screening of its customers on the same matching rules, as for PEP screening.

The Company will perform screening, at minimum, against the following sanctions lists:

  • UN Sanctions;
  • EU Sanctions;
  • Sanctions administered by the Office of Foreign Assets Control (“OFAC“);
  • Sanctions imposed under the Lithuanian government.

All matches (true hits) will be escalated to a Sanctions Officer for further action and processing.

Suspicious Activity Monitoring and Reporting

Where the Company identifies an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or other criminal offences or an attempt thereof or with regard to which the Company suspects or knows that it constitutes money laundering or terrorist financing or the commission of another criminal offence, a MLRO of the Company must report it to the FCIS immediately, but not later than within two working days after identifying the activity or facts or after getting the suspicion.

The Company and all its employees, officers and directors are prohibited to inform a person, its beneficial owner, representative or third party about a report submitted on them to the FCIS, an intention to submit such a report as well as about the commencement of criminal proceedings.

Data Retention

The Company must retain the documents and information which served for identification and verification of clients, no less than eight years after termination of the business relationship.

The Company implements necessary rules for protection of personal data upon application of the requirements arising from its obligations hereunder.

The Company is allowed to process personal data gathered upon implementation of these rules only for the purpose of preventing money laundering and terrorist financing and the data must not be additionally processed in a manner that does not meet the purpose, for instance, for marketing purposes.

Training

The MLRO shall ensure that Company’s employees are fully aware of their legal obligations under the AML/CTF regime, by introducing a complete employees’ education and training program.

The timing and content of the training provided is determined according to the needs of the Company. The frequency of the training can vary depending on the amendments of legal and/or regulatory requirements, employees’ duties as well as any other changes in the business model. The training program aims at educating the Company’s employees on the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.

Cooperation and Exchange of Information

The Company cooperates with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to the Company and replying to queries within a reasonable time, following the duties, obligations and restrictions arising from legislation. For any relevant requests please contact us at [email protected]. Please note that in case you represent the law enforcement agency outside of the European Union, procedure under the Mutual Legal Assistance Treaty (MLAT) may apply.