U.C.I has put in place an Anti-Money Laundering / Counter-Terrorist Financing Policy
and a Know Your Customer Policy (collectively, the “AML Policies”). The Policies are
revisited periodically and amended from time to time based on prevailing industry
standards and international regulations designed to facilitate the prevention of illicit
activity including money laundering and terrorist financing. All senior management and
employees of U.C.I are required to acknowledge and be familiar with the Policies.
This document covers AML Policies regarding U.C.I’s broker (non-exchange) services, which is U.C.I’s main business activity
Money Laundering Risks
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing is an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.
The risk of money laundering or terrorist financing on U.C.I is extremely low
does not engage in any exchange transactions between currencies, whether in crypto
or fiat. Clients can only deposit cryptocurrency (BTC) and withdraw the same
cryptocurrency (BTC), with no exchange activity happening in between. U.C.I uses third
party crypto transaction monitoring and source of funds software to track and tag funds
deposited into its platform, making it extremely unattractive for potential bad actors
attempting to move illicit funds
All Client funds remain in “virtual” currencies and are never converted to any other currencies. U.C.I requires KYC identification documents from all Clients before any transaction is made as an extra measure of risk reduction and compliance
AML/KYC Policies Framework
The Policies are designed to lay down a framework to:
Our Policies will be reviewed and updated on a regular basis to ensure appropriate procedures and internal controls are in place to account for both changes in regulations and changes in our business.
U.C.I adopts and maintains a Risk-Based Approach (“RBA”) towards assessing and containing the money laundering and terrorist financing risks arising from any transactions it has with Clients. The guidelines are as follows:
The Customer Identification Program is to be carried out:
When there shall be any suspicion of money laundering or terrorism financing activities, or where there shall be any doubt about the adequacy or veracity of previously obtained Clients’ identification data, the due diligence measures shall be reviewed, including verifying the identity of the Client again and obtaining information regarding the purpose and intended nature of the relationship with U.C.I
U.C.I does not serve clients from certain regions that are deemed high-risk or unwelcoming from a legal or regulatory perspective, including Cuba, Iran, North Korea, Syria, and the United States of America
U.C.I does not open accounts or transact with individuals that are on prescribed sanctions lists. U.C.I screens against United Nations, European Union, UK Treasury, US Office of Foreign Assets Control (OFAC), and other sanctions lists in all jurisdictions in which U.C.I operates
Politically Exposed Persons
U.C.I does not open accounts or transact with individuals who are Politically Exposed Persons (PEPs), or their family members. U.C.I screens all Clients against global PEP lists before they are allowed to establish a relationship with U.C.I
U.C.I accepts only natural persons as Clients, not legal entities. Upon registration, Clients go through an automated verification process where they submit:
All submitted client information is manually reviewed. For clients who cannot be verified through automated means (geolocation, algorithmic face detection, sanctions list check), enhanced due diligence is requested as described below.
Verification of identity is required by obtaining a high-resolution, non-expired copy of the Client’s government-issued ID (passport, national identity card, or a driver’s license). The submitted imaged requirements include:
Proof of residence
Verification of residence is required by obtaining a copy of an acceptable address proof document issued in the 3 months prior to establishing an account. The document must carry the Client’s name and address.
A valid proof of residence document can be:
Proof of residence documents must contain the Client’s name, address, and be dated less than 3 months ago.
Unique photo of Client
Further verification is requested from Clients by submitting a unique photo of themselves holding their government-issued ID as well as a unique handwritten note. In the photo, the Client must be visibly smiling. This allows U.C.I to easily prove that the Client’s picture was not stolen or photoshopped, and is being used exclusively for U.C.I.
The ID the Client holds in their hand:
The note the Client holds in their hand:
Based on the risk, and to the extent reasonable and practicable, we ensure that we have a reasonable belief that we know the true identity of our customers by using riskbased procedures to verify and document the accuracy of the information we get about Clients. Our AML Compliance Officer analyzes the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer.
We may decide to use the following non-documentary methods of verifying identity:
U.C.I implements and maintains internal controls for the purpose of ensuring that all of its operations comply with AML legal requirements and that all required reports are made on a timely basis
Monitoring and Reporting
U.C.I diligently monitors transactions for suspicious activity. Transactions that are unusual are carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary
Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and U.C.I may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.
The Compliance Officer initially makes the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, he makes the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be made.
For the purpose of the Policies, a “Suspicious Transaction” means a transaction or attempted transaction, which to a person acting in good faith,
Ongoing monitoring is an essential element of effective implementation. U.C.I diligently monitors transactions for Suspicious Transactions and other suspicious activity
Our AML Compliance Officer is responsible for ensuring that AML records are maintained properly
We document our verification, including all identifying information provided by a Client, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We keep records containing a description of any document that we relied on to verify a Client’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we retain documents that describe the methods and the results of any measures we took to verify the identity of a Client
We also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We retain records of all identification information for seven years after the account has been closed, or as long as reasonably necessary to comply with applicable regulations; we retain records made about verification of the customer's identity for seven years after the record is made, or as long as reasonably necessary to comply with applicable regulations
All new employees receive anti-money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML and KYC training annually. Participation in additional targeted training programs is required for all employees with day-to-day AML and KYC responsibilities.
Our training includes, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags (3) what employees' roles are in U.C.I’s compliance efforts and how to perform them; (4) U.C.I’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance
Our operations are regularly reviewed to check whether certain employees require specialized additional training. Written procedures are updated to reflect any such changes