KYC/AML
Policy

The Beldex AML/KYC policy (“Policy”) states the conduct of Beldex International Limited OU’s (“Company“, “Beldex“) approach to Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations set forth in Estonia, and in the countries of our operation and service. The Policy applies to the users (“Users”) of our services.

The AML/KYC policy is aimed to prevent and alleviate the involvement of Beldex in illegal activities including but not limited to money laundering, funding of terrorism, drug trafficking, etc.

Wherever in the policy, the context refers to a singular term, word or phrase shall also denote the plural and vice versa.

We follow a four-tier system for verifying the KYC documents of our users.

  • 1. Stringent User Verification
  • 2. Compliance Team
  • 3. Monitor User Activity
  • 4. Disclosure By User
  • 5. Risk Management

1. Stringent User Verification

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Beldex establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks. The purpose of customer due diligence is to prevent the use of assets and property obtained in a criminal manner in the economic activities of credit institutions and financial institutions and in the services provided by them whose goal is to prevent the exploitation of the financial system and economic space of the Republic of Estonia for money laundering and terrorist financing.

Identity Verification ProcedureUsers are required to provide correct and reliable identity verification documents and for such purposes that are mandated by the regulatory and statutory bodies of the various jurisdictions in which the User resides.

Beldex or its Compliance Team has the right to request additional ID information including but not limited to National ID (NID), UID, Passport, Driving Licenses, Utility bills, etc. Beldex has the right to investigate suspicious Users or monitor their transactions.

Once the User’s identity has been verified, Beldex is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity. Beldex reserves the right to refuse the deletion of User information stored in our systems, if it suspects, on reasonable grounds that the User is involved in unlawful activity

2. Compliance Team

The Compliance Team is an authorized representative of the Company and has the right and authority to suspend, freeze and investigate, any transaction or account that it reasonably deems on a verifiable cause to be involved in an illegal or suspicious activity that threatens to endanger the seamless functioning of the services or the availability of the services to other users.

Through thorough investigation and by nature of the User’s actions, the Compliance Team vests the sole right to act on behalf of Beldex to take corrective measures and mitigate the regulatory repercussions. The Compliance Team will be responsible for verifying the Companies AML policy is maintained and is in effect at all times.

The Compliance Team can

  • 1. Collect Users’ identification information.
  • 2. Establish and update internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations.
  • 3. Monitor transactions and investigate any significant deviations from normal activity.
  • 4. Implement a records management system for appropriate storage and retrieval of documents, files, forms, and logs.
  • 5. Update risk assessment regularly.
  • 6. Provide law enforcement with information as required under the applicable laws and regulations.

The Compliance Team is entitled to interact with and will be the primary point of contact with any law enforcement agency, which is involved in the prevention of money laundering, terrorist financing, and other illegal activity.

3. Monitoring User Activity

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

1. Crosschecking the Users against recognized “blacklists” (e.g. Sanctions lists, OFAC, etc.), and aggregating transfers from multiple data points. Placing suspicious Users on watch and service denial lists, opening cases for investigation where and when needed, sending internal communications via email and notices and filling out statutory reports, if applicable;

2. Case and document management

With regard to the AML/KYC Policy, Beldex will monitor all transactions occurring via its services and it reserves the right to:

  • Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Team
  • Request the User to provide any additional information and documents in case of suspicious transactions
  • Suspend or terminate User’s Account when Beldex reasonably suspects that such User has engaged in illegal activity under the law of the governing jurisdiction.

The above list is not exhaustive and the Compliance Team 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 authentic.

4. Disclosure By User

User has a legal obligation to inform the Company if, he/she is:

  • a politically exposed person;
  • a person whose place of residence or seat is in a country where no sufficient measures for prevention of money laundering and terrorist financing have been taken;
  • a person with regard to whose activities there is prior suspicion that the person may be involved in money laundering or terrorist financing;
  • a person with regard to whom international sanctions are imposed;

Legislation requires that the Company waives a transaction or the establishment of a business relationship if a person fails to provide sufficient information to identify the person or about the purpose of the transactions or if the operations of the person involve a higher risk of money laundering or terrorist financing. Also, legislation requires the Company to terminate a continuing contract without the advance notification term if the person fails to submit sufficient information for the application of customer due diligence measures

5. Risk Management

Beldex, 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, Beldex 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.

The policy may be amended to meet the requirements of newer AML/KYC regulations in our countries of operation and service.