Beaxy’s Anti-Money Laundering and Know Your Customer Policy (“AML/KYC”) Policy covers the following matters:
- Verification procedures.
- Compliance Officer.
- Monitoring Transactions.
1. Verification procedures
1.1. Identity verification
Beaxy’s identity verification procedure requires each User to provide Beaxy with reliable, independent source documents, data or information (e.g., national ID, international passport). Beaxy reserves the right to collect User’s identification information for AML/KYC Policy purposes.
User acknowledges and agrees that Beaxy may confirm the authenticity of documents and information provided by the Users and Beaxy reserves the right to investigate certain Users further at any time, verify User’s identity in an on-going basis and request up-to-date documents from the Users, even if User passed identity verification in the past.
1.2. Card verification
If the User uses payment cards in connection with Beaxy’s Services, Beaxy may require the User to provide additional documentation and information in accordance with instructions available on Beaxy’s Site.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by Beaxy, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Beaxy’s anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users’ identification information.
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
- Monitoring transactions and investigating any significant deviations from normal activity.
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
- Updating risk assessment regularly.
- Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
User acknowledges that Beaxy may monitor and analyze transactional patterns. Beaxy performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting, including:
- Regular check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
- Case and document management.
Beaxy reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when Beaxy has reasonable suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer may monitor User’s transactions on a day-to-day basis for any purpose, including to determine whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.