Appendix №6 to the Terms and Conditions of NBCGate Business
Summary of Anti-Money Laundering Policy and Know-Your-Customer Policy
1. General Provisions.
To ensure compliance with EU directives and FATF recommendations, NBCGate (operating under the NBCG brand) has established an Anti-Money Laundering Compliance Department and Know Your Customer (AML & KYC) Procedures that are mandatory for all employees and set forth the policy for interactions with any company and individuals using NBCGate services.
This document describes the basic points of the Company's internal AML policy:
2. Know your customer
NBCGate follows a strict KYC verification process to collect and verify all necessary information about the customer and individuals in the corporate structure. The opening of anonymous accounts is limited. Additional documents and information must be provided by the customer if requested by the Company. Failure to provide documents at the Company's request may result in suspension or termination of the relationship with the customer. Completion of the relevant KYC questionnaire, passing the necessary checks and video verification are also mandatory requirements of the Company.
3. Transaction Monitoring
NBCGate checks the client's reputation, geographic location, licenses, compliance with legal requirements, beneficial owners, managers and other authorized persons. The client is allowed to declare only one bank account for transactions, and all deposits and withdrawals are allowed only from/to the declared account. The company performs real-time verification of transactions. In case there are any signs of suspicious transactions on the Client's account, funds or crypto deposits from unreliable sources and/or any actions with signs of fraud, the Company reserves the right to conduct an internal investigation, block or close the Client's Account, cancel any payment and suspend the services.
4. Sub/Sanction Checks
NBCGate is protected from involvement in money laundering and terrorist financing by screening all customers (including controllers and beneficial owners), including sanctions checks. The company also has a general obligation to maintain up-to-date beneficial ownership information on clients and conducts regular follow-up checks on clients and their activities.
5. Geography of service provision
The Company does not provide services to individuals located in jurisdictions defined by the EU and FATF as high-risk and non-cooperative jurisdictions with strategic AML/CFT deficiencies, according to official lists (including Iran, North Korea, etc.). In addition, the Company does not provide services to U.S. citizens or residents.
6. Risk assessment
The Company takes a risk-based approach throughout its business, which requires identifying, assessing, understanding and mitigating AML & KYC risk, including consideration of risk factors such as customer, product, geography and service delivery channel.
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