AML & KYC Policy

Preamble

This AML & KYC Policy (hereinafter – the “Policy”) is an official document of Sabitzer OÜ (hereinafter – the “Company”) developed to combat money laundering, financial fraud and other illegal financial activities.

The AML & KYC Policy is a kind of quality standard for any international company and is also a sign of the company’s compliance with the most important global requirements in terms of financial transactions.

This Policy was developed specifically to provide users of this website or application of the Company (hereinafter – the “Service”) with additional information about the reasons and purposes of collecting certain personal information, as well as to provide information about the rights and obligations of users, about the responsibilities imposed on them by this Policy in accordance with international standards.

AML Policy

This AML Policy (Anti-Money Laundering, Money Laundering – money laundering; money laundering) aims to combat the concealment or misrepresentation of the true origin of funds obtained by criminal means, to prevent the use of the Company’s services by criminal entities for the purpose of money laundering, financing of terrorism or other criminal activities.

In accordance with the provisions of this AML policy, the user undertakes to:

  • comply with legal norms (including international ones) aimed at combating illegal trade, financial fraud, money laundering and legalization of illegally obtained funds;
  • exclude direct or indirect complicity in illegal financial activities and any other illegal operations using the Service.

The User guarantees the legal origin, lawful possession and right to use the funds transferred to the Company’s accounts.

In case of questionable transactions (including unjustified refunds or cancelations of payments), the Company has the right to request from the User copies of documents that allow to fully establish the source of origin of funds. Until the necessary information is received, the Company has the right to suspend the user’s transactions.

The Company’s refusal to conduct suspicious transactions is not the basis for legal liability for failure to fulfill its obligations to the user..

KYC Policy

KYC (Know Your Customer) policy is a kind of continuation of AML policy, implementing its basic concepts.

The main objective of the KYC policy is to identify and establish the identity of the counterparty, to counter anonymity in financial transactions, to combat financial fraud and other illegal financial activities.

In accordance with the KYC policy, the Company requests personal information from all users intending to enter into a financial relationship with the Company.

The Company cannot fully verify the accuracy of the information provided by users, nor whether the user has sufficient legal capacity to provide it. Responsibility for providing unreliable information, as well as information that the user is not authorized to provide, is fully on the user.

In case of doubts about the reliability of the information provided, the Company has the right to request the user to provide supporting documents, as well as their certification in accordance with the law (including international law). Until the necessary information is received, the Company has the right to suspend cooperation with the user, as well as his transactions.

Policy Update

This Policy may be supplemented and amended when such a need arises without the agreement of users. The Company has the right to make changes at its discretion in cases when the relevant changes are related to changes in the applicable legislation, as well as when the relevant changes are related to changes in the operation of the Service.

Changes in the Policy shall come into effect from the date of their official publication in the public domain on the Service.

In case of material changes, the Company undertakes to notify users using any available communication channels (e.g. by e-mail).

Other Provisions

The use of the Service by the User means his full and unconditional consent to this Policy. When visiting the Service for the first time, the User may be automatically sent a corresponding notification.

Date of publication: 01.06.2021