This document outlines the official Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance framework for digital financial services and online platforms. The objective is to prevent misuse of systems for illegal activities while ensuring a trusted, transparent, and secure environment for all users.
نازنین حمدانی | وبسایت رسمی و بلاگ
🎯 Purpose & Scope
This policy applies to all users who create accounts, initiate financial transactions, or interact with identity-sensitive services. It safeguards platform integrity through risk-based controls, identity verification, and continuous monitoring of accounts and transactions.
📜 Legal & Regulatory Framework
- EU Directive 2015/849 – Preventing financial system misuse
- EU Regulation 2015/847 – Transparency of fund transfers
- National AML regulations of the jurisdictions of operation
- GDPR & Data Privacy Standards protecting personal information
💡 What is Money Laundering?
Money laundering refers to concealing the illicit origin of funds to make them appear lawful. Examples include:
- Converting proceeds of crime into legitimate assets
- Concealing ownership or source of funds
- Using criminally derived assets knowingly
🏛️ Compliance Governance
The Compliance Officer and senior management are responsible for enforcing AML/KYC obligations. They oversee risk monitoring, reporting, and the integrity of the overall compliance framework.
✅ Three-Level Verification Process
Step 1: Basic Identity Verification
- Full legal name
- Date of birth and nationality
- Residential address
- Valid contact information
Step 2: Document Authentication
Triggered when transaction thresholds are met (example: equal or above USD 2,000):
- Government-issued ID document
- Face match through photo or selfie verification
- Proof of address when required
Step 3: Source of Funds / Wealth
Enhanced checks apply when transaction volumes increase, such as:
- Financial activity above USD 5,000
- Peer-to-peer transfers above USD 3,000
Supporting documents may include employment income, business ownership proof, investment records, or inheritance documentation.
📌 KYC Documentation Requirements
🪪 Identity Documents
- Passport, National ID, or Driver’s License
- Full document visible and readable
- Image must match user’s face
📍 Proof of Address
- Utility bill or bank statement issued within the last 90 days
- All edges visible and text legible
💳 Source of Funds Evidence
- Pay slips or employment contracts
- Tax filings, financial statements
- Investment or inheritance proof
🌍 Risk Categories & Regional Assessment
| Risk Level | Verification Policy |
|---|---|
| Low | Standard KYC process |
| Medium | Lower thresholds, enhanced review |
| High | Restricted access or application rejection |
📊 Ongoing Monitoring & Analytics
🧠 Automated Monitoring Systems
- Real-time fraud and anomaly detection
- Device, login behavior, and geolocation alerts
👁️ Human Review
- Compliance analysts review flagged accounts
- Verification of document authenticity and consistency
🚨 Escalation & Reporting
- Suspicious behavior reported to regulatory authorities
- Temporary or permanent service restrictions for noncompliance
📂 Enterprise-Wide Risk Assessment (EWRA)
Regular comprehensive assessments evaluate transaction types, customer demographics, payment channels, and emerging regulatory developments.
🗂️ Data Retention & Information Security
- Identity information retained for at least 10 years after account closure
- Transaction logs retained for a minimum of 10 years
- Strong data encryption and access control enforced
📚 AML Training & Accountability
- Mandatory AML training for relevant personnel
- Periodic refreshers aligned with regulatory updates
📣 Internal Reporting Requirements
Employees must report inconsistencies, suspicious documents, or unexplained fund movements directly to the Compliance Officer.
🔐 Privacy & User Rights
Personal data is used solely for compliance and legally required purposes. All processing aligns with GDPR standards and similar data protection laws.
📞 Support & Communication
Users may contact the compliance department for inquiries regarding identification, verification procedures, and AML protections.
📆 Policy Review & Maintenance
This policy is reviewed at least annually or sooner when legal changes or operational updates require revisions. All modifications must be approved by senior management.