AML Policy

1. INTRODUCTION

1.1. Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate risks of Ultiment s.r.o. related to money laundering and associated risks. This is a short extract of key principles of the internal Policy and should not be seen as a complete document.

1.2. Domestic and international regulations require Ultiment s.r.o. (Company) to implement effective internal procedures and mechanisms to prevent legitimisation of proceeds of crime and financing of terrorism, and to take action in case of any form of suspicious activity from its Customers.

2. IDENTIFICATION AND VERIFICATION

2.1. For the purposes of this Policy we may require you to provide us with the following information: all names and surnames, personal ID No., or the date of birth in the absence of personal ID No., place of birth, sex, permanent or other residence and citizenship. Also, we may request from you an internal or international passport, selfie with you ID-card, passport or bank card, bank statement, utility bill, tax document or other documents that we consider necessary for your identification. We may request from you video identification.

2.2. We may make the inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. You hereby acknowledge that we shall have the right to investigate you in case we determine you to be risky or suspicious. When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full.

2.3. We shall have the right to verify your identity on an on-going basis, including cases when your identification information has been changed or your activity seemed to be suspicious (unusual for you). We reserve the right to request up-to-date documents from you, even though you have passed identity verification in the past.

2.4. Customer’s identification information will be collected, stored, shared and protected strictly in accordance with the company’s Privacy Policy and related regulations that correspond to the GDPR requirements.

3. TRANSACTIONS MONITORING

We may monitor and analyze your transactions. We may perform compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. We may place you on watch and service denial lists, open cases for investigation where needed, send internal communications and fill out statutory reports, if applicable.

4. ANTI-MONEY LAUNDERING COMPLIANCE OFFICER

Our Anti-Money Laundering Compliance Officer (AMLCO) is ultimately responsible for implementing the regulations concerning AML. The AMLCO is a person of authority with access to any and all relevant information for the completion of his duties. You can contact our AMLCO by emailing us at: hello@nearpay.co. In the topic of the message you should indicate that you are contacting an AMLCO or have AML related questions.

5. RISK ASSESSMENT

5.1. The company shall apply appropriate measures and procedures, by adopting a risk-based approach, so as to focus its effort in those areas where the risk of Money Laundering and Terrorist Financing appears to be comparatively higher.

5.2. Further, the AMLCO shall monitor and evaluate, on an on-going basis, the effectiveness of the measures and procedures of this Policy.

5.3. The adopted risk-based approach that is followed by the company, and described in the Policy, has the following general characteristics:

• recognises that the money laundering or terrorist financing threat varies across Customers, countries, services and financial instruments;
• allows the Managing Director to differentiate between Customers of the company in a way that matches the risk of their particular business;
• promotes the prioritisation of effort and actions of the company in response to the likelihood of Money Laundering and Terrorist Financing occurring through the use of the services of the company.

5.4. The risk-based approach adopted by the company, and described in the Policy, involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the Money Laundering and Terrorist Financing risks faced by the company.

6. SANCTIONS

The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions.

7. PROHIBITED COUNTRIES

The Company does not provide services to persons residing in countries that:
- Were black-listed by international organizations due to money laundering risks;
- Consider services of the Company to be illegal and banned.