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AML/KYC Policy
1. Introduction
1.1. The Anti-Money Laundering Policy and "Know Your Client" (hereinafter referred to as "AML / KYC Policy") are aimed at preventing and reducing the possible risks of involvement of TRAFFER LTD (Company Number: 15960666) in any illegal activity.
2. The purpose of internal regulation
2.1. Resource traffer.uk adheres to practices and measures against money laundering and terrorist financing (AML). These measures are aimed at showing that TRAFFER LTD (Company Number: 15960666) takes seriously any attempts to use its service for illegal purposes.
3. Disclaimer
3.1. Resource traffer.uk warns users against attempts to use the traffer.uk website for money laundering, terrorist financing, fraud of any kind, as well as against using the service to advertise prohibited goods and services.3.2. The traffer.uk resource, its administration, employees and domain owners are not responsible for the illegal use of the service by third parties, the actions of intruders, and possible losses related to the use of the traffer.uk site.
4. Requirements
4.1. To prevent illegal transactions, traffer.uk sets certain requirements for all applications created by the User:4.1.1. The sender and recipient of the Application Payment must be the same person. Transfers in favor of third parties are strictly prohibited using the Services of the Service.4.1.2. All contact data that the User enters in the Application, as well as other personal data transmitted by the User of the Service, must be up-to-date and completely reliable.4.1.3. The User is strictly prohibited from registering or making payments using anonymous proxies, VPNs, Tor or any other anonymous Internet connections.
5. Verification Procedures
5.1. The traffer.uk service may require the User to provide the traffer.uk service with reliable, independent original documents, data or information (for example, a national identification card, international passport, bank statement). For such purposes, traffer.uk reserves the right to collect the User's identification information in order to comply with the AML/KYC Policy.5.2. traffer.uk will take measures to confirm the authenticity of documents and information provided by Users. The traffer.uk service reserves the right to investigate the cases of certain users whose identities have been identified as dangerous or suspicious.5.3. traffer.uk reserves the right to constantly check the identity of the User, especially when his identification information has been changed or his activity has turned out to be suspicious (unusual for a particular User). In addition, traffer.uk reserves the right to require users to have up-to-date documents, even if they have passed an authenticity check in the past.5.4. User identification information will be collected, stored, shared and protected in accordance with traffer.uk's Privacy Policy and applicable regulations.5.5. After confirming the user's identity, traffer.uk may refuse to provide services to the User in the event that traffer.uk services are used for illegal activities.5.6. traffer.uk has regulatory requirements to verify the source of funding to know that the sources of funds that Users use to make purchases are legitimate.
6. Responsible official
6.1. The duty of such an official is to monitor all aspects of traffer.uk's activities in combating the legalization of proceeds of crime, including money laundering and terrorist financing, including, but not limited to, the following methods:- collection of identification information of users;- creating and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required by applicable laws and regulations;- monitoring of transactions and investigation of any significant deviations from normal activity;- implementation of a records management system for appropriate storage and retrieval of documents, files, forms and journals;- regular updating of the risk assessment;- providing law enforcement agencies with the information necessary in accordance with current laws and regulations.6.2. The Anti-Money Laundering Compliance Officer has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities.
7. System functions
7.1. traffer.uk performs many compliance tasks, including data collection, filtering, record keeping, investigation management and reporting. System features include:- daily checking of users for the existence of recognized "black lists" (for example, OFAC),- aggregation of transmissions by several data points, - placement of users on watch lists and refusal to provide services,- opening cases for investigation where necessary,- sending internal messages and filling out mandatory reports, if possible;- case and document management.
8. Behavior analysis
8.1. traffer.uk verifies users not only by verifying their identity, but more importantly by analyzing their behavior in transactions. Therefore, traffer.uk relies on data analysis as a tool for risk assessment and suspicion detection.
9. Risk assessment
9.1. traffer.uk, in accordance with international requirements, applies practices, risk assessments to combat money laundering and terrorist financing. Applying risk assessment practices to combat money laundering, traffer.uk ensures the proportionality of measures to prevent or reduce money laundering and terrorist financing with identified risks.
10. Performing customer checks
10.1. If the administration of traffer.uk suspects that the user is trying to use the service for money laundering or to carry out any other illegal operations, the administration has the right to:
● suspend the user's payment transaction;● require identification documents from the User;● request any additional information and documents from the User in case of suspicious transactions;● ensure that reports of suspicious transactions are forwarded to relevant law enforcement agencies through the anti-money laundering officer.
11. Privacy
11.1. traffer.uk guarantees the confidentiality of customers in accordance with the privacy policy.11.2. traffer.uk and its employees undertake to keep confidential any facts discovered in connection with any dubious transaction. This obligation also applies to users of the Service and third parties to whom information about the agreement has been provided.11.3. Obligations regarding the confidentiality of employees of the traffer.uk Service remain valid after the termination of their work or any other contractual relationship with the traffer.uk Service, as well as after the transfer of such employees to another workplace. Disclosure of such information to state, law enforcement agencies and other entities in cases defined by law does not constitute a breach of the confidentiality obligation.11.4. The obligation of confidentiality, provided that the use of the disclosed information is limited to the prevention of the legitimization of the proceeds of crime and the financing of terrorism, cannot be applied to the disclosure of information between financial institutions forming a consolidated group that cooperates with the traffer.uk Service.
12. Conclusion
In connection with the above, traffer.uk bears no legal responsibility for its use for the purpose of money laundering, terrorist financing or advertising of prohibited goods and services, the service undertakes to take all possible and available measures to prevent attempts to use traffer .com.ua for the purpose of money laundering, terrorism financing or the purchase of prohibited goods and services.
