KYC and AML Policy

Know your Customer (KYC) and Anti-Money Laundering (AML) Policy and Procedures.

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Know your Customer (KYC) and Anti-Money Laundering (AML) Policy and Procedures

These procedures were written in English. To the extent any translated version of these procedures conflicts with the English version, the English version controls. Date of Last Revision: January 6, 2020



The Puut A/S (the “Company”) is supervised by the Danish Financial Supervisory Authority (Finantilsynet). As a regulated entity, the Company has in place policy and procedures to prevent money laundering and any activity that facilitates money laundering and/or the funding of terrorist or criminal activities in accordance with all applicable laws.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations, rules and laws and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The Company operates in compliance with ‘anti-money laundering (“AML”) and ‘know your customer’ (“KYC”) rules and regulations in the jurisdictions it operates in or sells products or services to and has developed this KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:

 - The Company is performing an enterprise-wide risk assessment to determine the risk profile of the Company.
 - The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company’s Board of Directors (the “Board”).
 - The Company is implementing internal controls throughout its operations designed to reduce risks of money laundering.
 -The Company performs know your customer (“KYC”) procedures on all virtual and/or exchange wallet holders.

POLICIES AND PROCEDURES


1.Virtual and exchange wallet holders Identification (Know Your Customer)



The Company shall collect the following information about each virtual and exchange wallet holders:

i. Private Transactions up to 50.00 Euro.


For contributions up to 50.00 Euro the virtual and exchange wallet holder’s profile must contains the following information:
 - First and last name of the contributor
 - Telephone number
 - Email address.

ii. Private Transactions up to 400.00 Euro/day and 1.000.00 Euro/year.


For contributions up to 400.00 Euro/day and 1.000,00 Euro/year the virtual and exchange wallet holder’s profile must contain the following information:
 - Name of the contributor
 - Social security number
 - Residential address
 - Date of birth
 - Nationality
 - Telephone number
 - Email address

iii. Private Transactions up to 1.350,00 Euro/day and 20.000,00 Euro/year (optional).


For the contributions up to 1.350,00 Euro/day and 20.000,00 Euro/year the virtual and exchange wallet holder’s profile must contain below information. In addition the virtual and exchange wallet holder should complete digital identity verification.
 - Name of the contributor
 - Social security number
 - Residential address
 - Date of birth
 - Nationality
 - Telephone number
 - Email address.

iv. Private Transactions up to 3.000,00 Euro/day and 40.000,00 Euro/year


 - Full Name
 - Telephone
 - Email address
 - Residential Address
 - Copy (front and back) of ID
 - Data collected from ID: Date of birth, Nationality, ID scan
 - Personal photograph (with ID in Hand)
 - Proof of address (utility bill)

v. Any Transactions equal to or above 3.000,00 Euro/day and 40.000,00 Euro/year


1.1.Individuals


 - Full Name
 - Telephone
 - Email address
 - Residential Address
 - Copy (front and back) of ID
 - Data collected from ID: Date of birth, Nationality, ID scan
 - Personal photograph (with ID in Hand)
 - A Description of Source of Funds

1.2. Companies Summary of information requested/gathered


 - Company Name
 - Company Address
 - Description of Business Activities
 - Government-issued business registration number or tax identification number
 - Copy of a recent trade register extract or similar document
 - Authorised Representative (Individual KYC process)

2. AML Screening


The Company shall screen each virtual and exchange wallet holder for matches in the following categories:
 - Global Sanctions List
 - OFAC Sanctions List.
PEPs - Screening virtual and exchange wallet holders for identification as a "politically exposed person". A PEP is a term describing someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they could hold.
Adverse Media - Screening virtual and exchange wallet holders against adverse media involves looking for any negative mentions of them in traditional news media and publicly available information more broadly. Any virtual and exchange wallet holder that has a match on any of the above categories shall be flagged and blocked pending review by the Company of the red flag. Virtual and exchange wallet holders will receive an email informing them that their wallets are under review. A follow-up email further inform them of the outcome of the review

3. Dispositions of AML Flags


Global Sanctions List - If the flag is a match on the Global Sanctions List, the Company shall deny virtual and exchange wallet holders access to virtual and exchange wallet service and promptly inform them about the status of their wallets.
PEPs - If the flag is a match on PEPs, the Company shall review the AML report and may request additional verification information.
 - After receiving any additional verification information, the Company shall provide the virtual and exchange wallet holders with notice of disposition.
 - Adverse Media - If the flag is a match on Adverse Media, the Company shall review the adverse media and make a determination on whether to allow the virtual and exchange wallet holder.