Last Updated: April 21, 2023
Please read this Know-Your-Customer/Anti-Money Laundering (“KYC/AML”) Policy carefully before using neocrypto.net website and our Services. You should read and understand it before accessing the Services, because this AML/KYC Policy is one of the documents that allow the Client to use the Services of Neocrypto correctly and safely. If you are in any doubt about any of the contents of this document, you should obtain independent professional advice.
2. DefinitionsMoney Laundering (hereinafter ML) – is a set of activities with the property derived from criminal activity or property obtained instead of such property with the purpose to conceal or disguise the true nature, source, location, disposition, movement, right of ownership or other rights related to such property; convert, transfer, acquire, possess or use such property for the purpose of concealing or disguising the illicit origin of property or of assisting a person who is involved in criminal activity to evade the legal consequences of his or her action.Terrorist Financing (hereinafter TF) – means the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism in the meaning of applicable legislation.International Sanctions – list of non-military measures decided by the European Union, the United Nations, another international organization, the government of the Republic of Estonia or the government of the Republic of Lithuania and aimed to maintain or restore peace, prevent conflicts and restore international security, support and reinforce democracy, follow the rule of law, human rights and international law and achieve other objectives of the common foreign and security policy of the European Union.Compliance Officer (CO) or Money Laundering Reporting Officer (MLRO) – representative appointed by the Management Board responsible for the effectiveness of the AML/CTF Policies, conducting compliance over the adherence to the relevant policies and serving as contact person of the FIU or the FCIS.FIU - Financial Intelligence Unit of the Ministry of Finance of Estonia.FCIS - Financial Crime Investigation Service of Lithuania.Business Relationship – a relationship established by Neocrypto in its economic and professional activities with the Client.Client – a natural person, who uses services of Neocrypto.Transaction – an exchange of fiat currency against virtual currency conducted by the Client through Neocrypto.Beneficial Owner – is a natural person, who:
3. Compliance Officer or Money Laundering Reporting OfficerThe MB appointed a CO whose principal tasks are to monitor the compliance of the Rules with the relevant laws and regulations; compile and keep updated the data regarding countries with low tax risk, high and low risk of ML and TF and economical activities with great exposure to ML and TF; instruct and update the staff; report to the MB on compliance with the Policy; collect, process and analyze the data received from staff or Clients concerning suspicious and unusual activities; receive internal disclosures, make reports and collaborate with the FIU or the FCIS on events of suspected ML or TF; make proposals on remedying any deficiencies identified in the course of checks.
4. Application of due diligence measuresNeocrypto shall determine and take due diligence (hereinafter DD) measures using results of conducted risk assessment, and provisions of national risk assessment, published on the web page of the Ministry of Finance of Estonia and Lithuania.DD measures shall include the following procedures:
5. Identification of a personUpon implementing DD measures the following person shall be identified:
6. Establishing the purpose and actual substance of a TransactionIn order to screen out suspicious or unusual Transactions and the purpose and actual substance of a Transaction, Neocrypto shall take the following actions:
7. Risk assessmentNeocrypto conducts risk-assessment of its activities and Clients, and establishes a risk profile of a Client based on information gathered under the Rules and applies relevant level of due diligence measures accordingly.
9. Storage of DataThe data is stored in a written format and/or in a format reproducible in writing and, if required, it shall be accessible by all appropriate staff of the Company.The originals or copies of the documents, which serve as the basis for identification a person, and of the documents serving as the basis for establishing a Business Relationship, shall be stored for at least five (5) years following the termination of the Business Relationship if you are Client of MainCoin OÜ. The data of the document prescribed for the digital identification of a Client, information on making an electronic query to the identity documents database, and the audio and video recording of the procedure of identifying the person and verifying the person’s identity shall be stored at least five (5) years following the termination of the Business Relationship. MainCoin OÜ shall preserve documents, copies of documents and information related to the performance its the obligations provided for in subsections § 25 22–25, 27 и 28 of the Money Laundering and Terrorist Financing Prevention Act of the Republic of Estonia for five (5) years after the termination of the Business Relationship with the Client. If you are Client of UAB Effective Global Solutions the data specified above shall be retained for eight (8) years after the expiry of the Business Relationship or the completion transaction.Information regarding Transactions reported to the FIU and the FCIS shall be stored by the CO and shall be accessible only to MB.
10. Reporting of suspicious TransactionNotification of the CO:Any circumstances identified in the Business Relationship are unusual or suspicious or there are characteristics which point to ML, TF, or an attempt of it, shall promptly escalate to the CO.The CO shall analyze and forward the respective information to the MB.Notification of the FIU or the FCIS:The CO shall decide whether to forward the information to the FIU or to the FCIS and the MB shall decide whether to terminate the Business Relationship.It is prohibited to inform any third persons, including other staff of Neocrypto, of the fact that information has been reported to the FIU or the FCIS, and the content of the reported information, except for the MB/CO.
11. Implementation of International Sanctions:Neocrypto is required to implement International Sanctions in force.Neocrypto conducts screenings and draws special attention to all its Clients (existing and new), to their activities and to the facts and indicators which refer to the possibility that the Client is a subject to International Sanctions in force.
12. Restricted jurisdictionsAlbania, Afghanistan, The Bahamas, Barbados, Botswana, Burkina Faso, Cambodia, Cayman Islands, Cuba, Democratic Republic of Korea (DPRK), Haiti, Ghana, Jamaica, Iran, Iraq, Malta, Mauritius, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Trinidad and Tobago, Uganda, Vanuatu, Yemen, Angola, Burundi, Central African Republic, Congo, Congo (Democratic Republicof the), Guinea-Bissau, Liberia, Lybia, Mali, Sierra Leone, Somalia, Cote d’Ivoire, The United States of America (USA), Zimbabwe.Neocrypto reserves the right to choose markets and jurisdictions in which it operates, and may also restrict or refuse provision of its services in other countries, territories or regions if deemed necessary by its own risk appetite or required by laws, competent authorities or sanctions programs. You should inform us immediately if you become a resident in any of the Restricted jurisdiction. You understand and acknowledge that if it is determined that you have given false representations of your location or place of residence, Neocrypto reserves the right to take any appropriate actions with compliance to the local jurisdiction, including termination of your access to Neocrypto’s Services.IF YOU HAVE ANY QUESTION REGARDING PRESENT AML/KYC POLICY OR OUR RULES OR NEED ANY ADDITIONAL DETAILS / INFORMATION / EXPLANATIONS, PLEASE CONTACT US DIRECTLY.
By clicking "Accept All Cookies" you agree that cookies are stored on your device to improve site navigation, analyze website usage and assist in our marketing efforts. For more detailed information about the cookies we use, see our Cookies Policy.