The Anti-Money Laundering, Countering Financing of Terrorism and Know Your Customer Policy (hereinafter - the "AML/CFT Policy") of SkylineCrypto is designated to prevent and mitigate possible risks of SkylineCrypto being involved in any kind of illegal activity.
Money laundering is defined as
The conversion or transfer of assets resulting from illegal activities or the substitution of assets in place of such property, with the knowledge that the assets are derived from criminal activities or from participating in such activities, is undertaken to conceal or alter the unlawful origin of the assets or to aid any person involved in such activities to evade legal consequences.
The acquisition, possession, or utilization of assets derived from criminal activities or assets obtained in place of such property, with the awareness at the time of receipt that these assets originated from criminal activities or participation therein.
Concealing or altering the genuine nature, source, location, disposition, movement, rights related to, or ownership of assets derived from criminal activities or assets obtained in place of such property, with the knowledge that these assets come from criminal activities or participation in such activities.
Money laundering also encompasses participating in, associating to commit, attempting to commit, and aiding, abetting, facilitating, and counseling the commission of any of the aforementioned activities.
Terrorist financing is defined as providing financial support for an act of terrorism and its commission, as well as financing and supporting travel for the purpose of terrorism.
Both international and local laws and regulations mandate that SkylineCrypto establish effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Additionally, it requires taking action in the event of any suspicious activity by its users.
AML/CFT Policy covers the following matters
1. internal controls
2. compliance officer;
3. training of personal;
4. verification procedures;
5. monitoring, risk assessment and risk-based approach;
6. AML/CFT program audit.
7. Internal Controls
We have designed a structured system of internal controls in order to comply with applicable Anti-Money Laundering, Countering Financing of Terrorism (hereinafter - the "AML/CFT") laws and regulations, including, but not limited to:
• establishing customer's identity and verifying the information provided;
• establishing special regime for dealing with customers which are politically exposed persons (PEP);
• the identification of unusual activity and facilitating the reporting of suspicious activity (SAR);
• record keeping of customer documentation and transactional history.
Compliance Officer
The individual designated as the Compliance Officer, duly authorized by SkylineCrypto, is tasked with the development and enforcement of effective Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) measures. The Compliance Officer is obligated to report any breaches of AML/CFT procedures and holds responsibility for the collection and filing of Suspicious Activity Reports (SARs).
The Compliance Officer's role encompasses the supervision of all facets of SkylineCrypto's anti-money laundering and counter-terrorist financing efforts, including, but not limited to:
• Developing and updating internal policies and procedures for the creation, review, submission, and retention of all required reports and records as per applicable laws and regulations.
• Collecting users' identification information, verifying the provided information, and implementing a records management system for the proper storage and retrieval of documents, files, forms, and logs.
• Gathering and analyzing information related to unusual transactions or circumstances suspected of money laundering or terrorist financing, conducting investigations into any identified unusual or suspicious activities.
• Reporting to the appropriate authorities in cases of suspected money laundering or terrorist financing, and providing law enforcement with necessary information as mandated by applicable laws and regulations.
• Periodically submitting written statements on compliance with legal requirements to the management board.
• Organizing employee training sessions.
• Performing other duties and obligations related to compliance with legal requirements, including regular updates to risk assessments.
• The Compliance Officer is authorized to collaborate with law enforcement agencies involved in the prevention of money laundering, terrorist financing, and other illicit activities.
Training
Every employee undergoes comprehensive Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) training, supplemented with job-specific guidance. This training occurs at least once every twelve (12) months to ensure that all employees are well- informed and operate in accordance with relevant laws and regulations. In cases where new laws or regulations are adopted, or when required by law, employees undergo additional training. Additionally, new hires complete pertinent training before starting their work.
The training program undergoes regular updates to align with current laws and regulations, ensuring that employees stay informed about any changes in the regulatory landscape. This commitment to ongoing training underscores the organization's dedication to maintaining a workforce that is knowledgeable and compliant with the latest legal requirements in the realm of AML/CFT.
Verification Procedures
SkylineCrypto has established its own customer verification procedures in alignment with Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) frameworks. Prior to entering into business relations with customers, clients, or contractors, the company conducts due diligence and Know Your Customer (KYC) checks.
For individuals seeking to open an account, their identity, provided information, and submitted documents undergo verification against sanctions and watch lists, including Politically Exposed Persons (PEP) lists. SkylineCrypto employs specialized tools and a structured system for this purpose.
In the case of legal entities, including their owners, shareholders, and beneficiaries, SkylineCrypto implements enhanced due diligence, KYC, and compliance procedures.
Specialized enhanced identification, KYC, due diligence, and compliance procedures are applied to customers identified as PEPs, regardless of their place of residence.
Monitoring, risk assessment, and a risk-based approach are integral to SkylineCrypto's AML/CFT efforts. The company employs a specially developed system, including high- performance tools, for customer transaction monitoring, risk assessment, and the detection of suspicious activities.
A risk-based approach guides SkylineCrypto in combating and preventing money laundering and terrorist financing. A compliance risk profile is calculated upon entering into relations, categorized as Low, Medium, or High, and is routinely recalculated.
Ongoing transaction monitoring ensures the detection of unusual or suspicious transactions compared to the customer profile. The determination of unusual transactions relies on a
subjective assessment, considering the knowledge of the customer, their financial behavior, and the transaction counterparty.
If a transaction is inconsistent with a customer's known activities or habits, it may be deemed suspicious. Data and transaction monitoring tools identify unusual patterns of customer activity. The Compliance Officer reviews and investigates, deciding whether to file a Suspicious Activity Report (SAR) or not.
SAR filings are confidential, known only to SkylineCrypto's employees involved in the investigation and reporting process. All records are retained for a minimum of five (5) years and are accessible upon official request by authorized examiners, regulators, or law enforcement agencies.
Any SkylineCrypto staff member observing atypical transactions, unable to attribute them to a lawful activity or known source of income, is obligated to inform the Compliance Officer.
AML audit
The Compliance Officer holds the responsibility of conducting an Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) audit at least once every two years, as stipulated by internal policies and procedures. Other audit requirements are outlined within the internal framework.
We diligently apply due diligence measures, specifically:
• Upon establishment of a business relationship.
• Upon verification of information gathered during the application of due diligence measures or in cases of doubts regarding the sufficiency or truthfulness of previously gathered documents or data during updates.
• Upon suspicion of money laundering or terrorist financing.
• In other cases, including those precisely prescribed by law, and in instances of identifying "red flags" in accordance with internal procedures.
The preservation of data is a key aspect of our compliance efforts:
• Retention of the originals or copies of documents serving as the basis for the identification and verification of persons, as well as documents establishing a business relationship, for a minimum of five years after the termination of the business relationship.
• Retention of documents related to a transaction, including those serving as the basis for notification obligations, for no less than five years after the completion of the transaction or the fulfillment of reporting duties.
Our business relationship monitoring practices include:
• Checking transactions within a business relationship to ensure alignment with our understanding of the customer, its activities, and risk profile.
• Regular updating of relevant documents, data, or information gathered during the application of due diligence measures.
Identifying the source and origin of funds used in a transaction.
Paying heightened attention to transactions likely linked with money laundering or terrorist financing, especially complex, high-value, and unusual transactions or patterns lacking a reasonable economic or lawful purpose or not characteristic of the given business specifics. Giving extra scrutiny to business relationships or transactions involving customers (or payment providers, etc.) from high-risk third countries or countries specified by law as having factors increasing geographical risk.
These measures collectively contribute to our commitment to robust AML/CFT practices, ensuring the integrity of our business relationships and transactions.
