In order to protect the funds of our clients and to ensure compliance with the world trade standards PROTERON LIMITED OÜ (hereinafter referred as “The Company”) works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities:
- Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015,
- Money Laundering and Terrorist Financing Prevention Act,
- Payment Institutions and E-money Institutions Act.
The Company AML Policy is designed to prevent money laundering by meeting the Estonian AML/CFT legislation obligations including the need to have adequate systems and controls to mitigate the risk of being used to promote financial crime. The Company reserves the right to refuse registration to persons from jurisdictions that do not meet international AML/CFT standards.
To monitor compliance with the legislation, the Company develops Anti- Money Laundering and Know Your Client (AML/KYC) procedures, which are mandatory for compliance by all employees of the Company and policy-defining interactions with persons who enter into an Agreement with the Company and become clients of the Company (hereinafter referred to as the "Clients of the Company").
The Company compliance shall to ensure that the Company's activities comply with international standards of Anti-Money Laundering Policy and all documents provided by the Clients are relevant and comply with the requirements of the law.
Regulations require the Company to have:
- Policies and procedures to prevent them from being used by money launderers.
- Employees trained in these procedures and in anti-money laundering law.
- Checks and controls to ensure that the policies and procedures are working.
- Have internal and external measures in place for the disclosure procedures for suspicious transactions.
Policies, controls and procedures sets out the requirement for relevant businesses to establish and maintain appropriate and risk-sensitive policies and procedures.
These policies and procedures must:
The main principles encompassed by money laundering regulations can be described as Risk Based Approach (RBA).
A risk based approach is an approach which is a cost effective and proportionate way to manage the risk of money laundering. In implementing a risk based approach, the Company should consider: the risk posed by the Client.
The following customers and behavior should be considered riskier:
The Company should monitor the risk of money laundering by being aware of patterns of business transactions, including:
Risk based control procedures include:
If the Company has assessed that the business relationship with a Client pose a high risk it will apply the following additional measures:
Obtaining the information relating to the source of the funds or the wealth of the Client will be required (this will be done via e-mail or phone);
Seek further information from the customer or from Company’s own research and third party sources in order to clarify or update the Client’s information, obtain any further or additional information, clarify the nature and purpose of the Client’s transactions with Company.
When obtaining information to verify the Client’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinise details of the person’s employment status or business/occupation. The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business etc.).
The Company will conduct ongoing Client due diligence and account monitoring for all business relationships with Clients. It particularly involves regularly reviewing and refreshing Company’s view of what its Clients are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Client. It can also include anything that appears to be a material change in the nature or purpose of the Client’s business relationship with Company.
A Nominated оfficer is the person within an organization who is responsible for overseeing all activity related to anti-money laundering matters.
The Nominated Officer's responsibilities include:
Training on the AML Policy will be given to all new employees before they start work and will be repeated every 12 months as a refresher. The staff has to be instructed in the risks of money laundering/terrorism financing and in the identification and reporting of unusual activities or transactions which may prove to be suspicious. We will also carry out training where there has been a substantial change in the law, and there will be monthly training sessions on various other relevant topics.
The Nominated Officer will provide a monthly review of business activity with the staff, to ensure all procedures and processes have been adhered to with all customer registrations and ensuring that business transactions have been completed correctly.
Politically exposed persons (PEP) are persons that are entrusted with prominent public functions, whether in the Republic of Estonia.
- is an individual who performs or performed prominent public functions, including heads of state, heads of government, minister and deputy or assistant minister, a member of parliament, or parliament, as a legislative body, a member of the governing body of the party body of the Supreme Court and the Supreme Court Member of the State Control Committee and a member of the supervisory board of the central government, the head of an international organization, the deputy head and a member of the management body or an equivalent person, otorrhea not an official of the central or sub-national level;
- a local public person is a person specified in the above who performs or performed the basic functions of state authority in Estonia, the other Contracting Party of the European Economic Area or the European Union institution;
- a family member is a politically significant person or a local politically exposed spouse or spouse of a person is the equivalent of a person recognized as a politician or a politically exposed person by a child of the person and child of the spouse or equivalent of an addicted person and politically injured or a local senior politician;
- close to a co-worker an associate is an individual who realizes that he is a legal person or person who is the actual owner or co-owner of a politically irradiated person or a local politically significant person or has close business relations with a politically irradiated person or local politically significant persons; an individual who is the sole beneficial owner of a legal entity or legal entity that is known to have been created in the interests of a person with a national or local education.
If the Client is a politically exposed person, family member or known close associate of one, then we must put in place the following enhanced due diligence measures:
- obtain senior management approval before establishing a business relationship with that person,
- take adequate steps to establish the source of wealth and source of funds that are involved in the proposed business relationship or transaction,
- conduct enhanced ongoing monitoring where we’ve entered into a business relationship.
In this connection, by concluding the Agreement with the Company, the Client shall fully and unconditionally accept the terms of this policy, agrees with the following rules and undertakes to observe them:
If another legal entity is a shareholder of a legal entity, the documents specified in clauses 1.2.1.-1.2.5 shall be submitted with respect to this shareholder.
We realize that some of the above documents may not exist in some jurisdictions. In that cases, please send the best local equivalent.
In order to protect the funds of our clients and to ensure compliance with the world trade standards, works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities the Company supports cards with 3D-secure only.
The Company additionally collects and stores Customer's information on their payment card as well. Payment card details with photos will be asked to upload before the cryptocurrency purchase. The provided documents will be investigated in 24 hours. The customer will be informed about the results by the e-mail.
For the Customers verification (KYC 2 level) The Company requires the following documents:
The account will be unverified (KYC 1 level) until the above listed documents will be presented and checked. According to the customers’ level of verification, the different limitations to use service are applied. The detailed chart is presented in the Fees & Limits.
All collected information is completely confidential and can be disclosed only to the local or other compliance regulators. The company reserves the right at any time without informing in advance and without disclosing any reason, suspend the operation of Customer account. The company must notify the Customer about the matter just after account suspending.