Introduction

Swipelux Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Swipelux being involved in any kind of illegal activity.

Both international and local regulations require Swipelux to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

  1. Verification procedures
  2. Compliance Officer
  3. Monitoring transactions
  4. Risk assessment

1. Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Swipelux establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).

Swipelux’s identity verification procedure requires the User to provide Swipelux with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Swipelux reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Swipelux will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Swipelux reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Swipelux reserves the right to verify the User's identity on an on-going basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular User). In addition, Swipelux reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Swipelux Privacy Policy and related regulations.

Once the User’s identity has been verified, Swipelux is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

Swipelux is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Swipelux will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by Swipelux, 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 Swipelux’s anti-money laundering and counter-terrorist financing, including but not limited to:

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

Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Swipelux relies on data analysis as a risk-assessment and suspicion detection tool. Swipelux performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

With regard to the AML/KYC Policy, Swipelux will monitor all transactions, and it reserves the right to:

The above list is not exhaustive, and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

4. Risk assessment

Swipelux, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Swipelux is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.