ANTI – MONEY LAUNDERING AND KNOW YOUR CUSTOMER POLICY
This Anti-money Laundering and Know Your Customer Policy is an electronic agreement between you (hereinafter the “User”) and PayMIR that applies to your use of this Site, all services, products and content provided by PayMIR.
1. GENERAL PROVISIONS
1.1. By creating a User account on the Site or by using any of the Services, you acknowledge that you completely agree to this Agreement. 1.2. The purpose of the Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is to identify, prevent and mitigate possible risks of Paymir.com being involved in illegal activity. 1.3. In conformity with international and local regulations PayMIR has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users. 1.4. AML/KYC Policy includes Verification procedures, Compliance Officer, Monitoring Transactions, Risk Assessment.
2. VERIFICATION PROCEDURES
2.1. Customer due diligence has become one of one of the international standards for preventing illegal activity. Thus, PayMIR has implemented its own verification procedures within the rigorous standards of anti-money laundering and “Know Your Customer” procedures. 2.2. The PayMIR identification procedure requires the User to provide PayMIR with reliable, independent source documents, data or information. Documents required include: valid picture identification such as passport (bio pages), national ID card, driving license, or other forms of government-issued identification; proof of address no older than three months is required (utility bill, government tax statement, bank statement, credit card statement, insurance statement); selfie photo (User holding his ID document). 2.3. PayMIR will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used, and PayMIR reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious. 2.4. PayMIR reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, PayMIR reserves the right to request from the Users current documents, even if they have been authenticated in the past. 2.5. Information about the user's identification will be collected, stored, shared and protected strictly in accordance with the PayMIR Privacy Policy and relevant rules. 2.6. Users who intend to use payment cards for the purpose of consuming services may be required to undergo a card check in accordance with the instructions of PayMIR. 2.7. For the purpose of verification Business User Account the User has to provide the following documents: Certificate of Incorporation and business registration; Memorandum and Articles of Association (which evidence the powers that regulate and bind the company), Authorized Signature List, Current Officer Register List, Current Director Register List, Names of Ultimate Beneficiary(s), Shareholder List, Proof of Registered Office and Business Address (if different from registered office). 2.8. If the corporation filing to open a User account is owned/controlled by another corporation (and for each additional corporate layer) PayMIR may ask for further documentation to fully understand ultimate control and beneficiary. 2.9. Each director, shareholder (owning 20% or more in the company), control officer/person, authorized signatory and ultimate beneficiary is required to provide proof identity and documents required according to art.2.2. 2.10. For the purpose of AML/KYC Policy PayMIR has the right to ask for any additional document and information if required.
3. COMPLIANCE OFFICER
3.1. The Compliance Officer is the person, duly authorized by PayMIR, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. 3.2. It is the Compliance Officer’s responsibility to supervise all aspects of PayMIR anti-money laundering and counter-terrorist financing, in particular 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. 3.3. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
4. MONITORING TRANSACTIONS.
4.1. The Users are known not only by verifying their identity by analyzing their transactional patterns. Therefore, PayMIR relies on data analysis as a risk-assessment and suspicion detection tool. PayMIR performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. 4.2. System functionalities include: daily 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. 4.3. In connection with the AML/KYC Policy, PayMIR will monitor all transactions and it 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 PayMIR has suspicion that such User engaged in illegal activity. 4.4. If necessary PayMIR always uses the block chain monitoring tool. 4.5. PayMIR always provides specific verification and if necessary manual processing of transactions on the amount of equivalent or more than 1000,00 USD or its equivalent in any fiat currency or cryptocurrency.
5. RISK ASSESSMENT.
5.1. PayMIR, in line with the international requirements, has adopted a risk-based principle to combating money laundering and terrorist financing. This makes PayMIR to be able to ensure that measures to prevent an illegal activity are commensurate with the identified risks. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
Copyright © PayMIR Ltd 2015-2020. All rights reserved
PayMIR is operated by: Paymir Global OÜ, registry code 14866944, with legal address is Harju maakond, Kuusalu vald, Pudisoo küla, Männimäe/1, 74626, holder of licences FVR001335 “Providing services of exchanging a virtual currency against a fiat currency” and FRK001215 “Providing a virtual currency wallet service”