Terms and Conditions
1.1 Please read these Terms and Conditions carefully before using the website chainblocks.net owned and operated by SoltCorp. Ltd., registration number: 25624 BC 2019, address: C / o Suite 305, Griffith Corporate Center, Beachmont, Box 1510, Kingstown, Saint Vincent and the Grenadines.
1.2 By accessing or using the Service, you agree to be bound by these Terms and Conditions. If you do not agree with any part of the Terms and Conditions, you cannot access and use the Service.
These documents were written in English. In the event of any inconsistency between the English version and the translation, the English text shall prevail.
The company has updated its Privacy Policy in accordance with the European Union General Data Protection Regulation (GDPR).
The company and its affiliates (hereinafter “we”, “us” or “our”) are committed to protecting and respecting your privacy.
The company does its best to ensure the privacy, confidentiality and safety of its Clients, both during and after interaction with the Company, to the greatest extent possible.
The purpose of this Privacy Policy is to inform you about the following:
persons responsible for protecting your information;
the types of Personal Data we may collect about you;
ways of using such data;
the sources we use to collect information about you;
our use of information about IP addresses and cookies;
any cases of disclosure of Personal Data to third parties;
your right to correct, update and delete Personal Data;
security measures that we use to prevent loss, misuse or alteration of Personal Data under our control.
Collection and use of Personal Data
We may collect your personal data if you use the Site or open an Account in order to use our Services or perform any Transactions on the chainblocks.net website.
The types of Personal Data we collect may include the following:
Your name;
Your photo;
your address;
Your phone number;
Your e-mail address;
your login;
your IP address (s) and geolocation;
information about your device and browser;
your bank details, including account numbers;
your date of birth; your operations.
We may use your Personal Data to:
to allow you to open and manage an Account on the chainblocks.net website, to carry out Transactions, to respond to your inquiries if you contact us;
analyze the use of our Site as required by legal regulations;
provide you with information about products and promotions of our company and third parties that may be of interest to you, but only if you have given your explicit consent to receive such information;
market research, for example, study the needs and opinions of our Clients on issues such as the effectiveness of our company, etc.
We will only process your Personal Data for the purposes for which it was provided to us.
Sources of information
We collect information about you from several sources, including but not limited to:
Your profile at
Your social media profiles (Facebook, Google)
Cryptocurrency blockchains (Bitcoin, Litecoin, Ethereum, BitcoinCash blockchains)
2 IP Addresses
We may collect information about your computer, including, if possible, information about your IP address, operating system and browser type, for system administration purposes and to provide aggregated information to our advertisers. These are general statistics about the actions and patterns of Internet use of our clients as a whole, and not for each individual person.
3 Cookies
We use a browser feature known as cookies to authenticate your computer. Cookies are usually stored on your computer’s hard drive. The information generated by cookies is used by us to evaluate the performance of our Site, analyze trends and manage the company. This information allows us to determine which sections of our Site are the most popular and what difficulties visitors may have when accessing our Site. With this knowledge, we can improve the quality of our services by recognizing and providing you with the most desirable features and information, as well as solving access problems. We also use cookies and/or a technology known as web bugs or blank GIFs, which are usually stored in emails, to confirm receipt and response to our emails and to provide a personalized experience for each client using our Site.
We work with third-party service providers to better understand how visitors use our Site. Our service providers place cookies on your computer’s hard drive and receive information of our choice that tells us about how visitors navigate our site, what products they browse, and general information about Transactions. Our service providers analyze this information and provide us with summarized reports. The information and analysis provided by our service providers will be used to help us better understand the interests of visitors to our Site and how best to serve those interests. Information collected by service providers may be linked to and combined with information that we collect about you when you use the services of the company. According to the agreement, our service providers may use the information obtained from our Site solely to assist our company.
By using our site, you agree that we may use cookies for the purposes set out above.
4 Disclosure of Personal Information
We use Personal Data for the purposes specified at the time you provide such data to us, and / or otherwise for the purposes set out in this Privacy Policy and/or in any other way permitted by law. We may transfer Personal Information that you provide to us, our affiliates, agents, representatives, trusted service providers, and contractors for these limited purposes. We may also transfer Clients’ Personal Data to financial institutions, insurance companies or other companies in the event of a merger, division, or other corporate reorganization. We may also transfer Clients’ Personal Data to law enforcement or regulatory authorities where required by law. We oblige any third parties that gain or have access to Personal Data to protect such Personal Data and use it only to provide the services they provide for you or for the company unless otherwise provided or permitted by law. We guarantee that any such third party will be aware of our obligations under this Privacy Policy, and we will enter into contracts with such third parties under which they will be bound by terms that protect any Personal Information disclosed to them, no less than obligations that we make to you under this Privacy Policy or that are imposed on us under applicable data protection laws.
In particular, when necessary and permitted by law, we may share information about you with the following persons:
4.1 Third-party data verification service providers (i.e. identity and address verification);
4.2 Acquiring banks and card-issuing banks;
4.3 Payment Processing Partners;
4.4 Our service providers;
4.5 To banks or other financial institutions when handling claims or refunding payments;
4.6 Representatives of government and regulatory authorities upon request;
Please note that we work with partners in different countries, so your information may be processed and stored in different jurisdictions, but only in accordance with the laws of that particular jurisdiction.
We strive to ensure the security of your personal data at all times using secure data transmission channels, contractual obligations, and other means (for example, we only work with trusted partners who use adequate data protection measures).
5 Correction / updating / deletion of personal data
You have the right to access your Personal Data and can request the correction, updating, and blocking of inaccurate and/or incorrect data by sending an email to the following address: support@chainblocks.net
You can also send a request to delete or destroy both the Account and Personal Data at support@chainblocks.net. The company will process your request as long as it does not conflict with its legal and regulatory obligations.
Upon your written request, we will inform you about the Personal Data we hold about you, as well as about the use and general disclosure of your Personal Data. We will also provide you with a copy of the Personal Information we have retained. We may charge a minimum fee for accessing your Personal Information.
6 Security
We have taken all security measures to maintain confidentiality and protect your Personal Data from loss, misuse, alteration or destruction. Only authorized company personnel have access to your Personal Data, and this personnel should treat such data as confidential information.
The chainblocks.net website is owned by SoltCorp. Ltd. with registration number 25624 BC 2019.
Our address is C / o Suite 305, Griffith Corporate Center, Beachmont, Box 1510, Kingstown, Saint Vincent and the Grenadines.
Our official email address is support@chainblocks.net Phone number: +441274797018;
Existing security measures are subject to periodic review, taking into account legal and technical changes.
7 Retention of Personal Data
We will only retain your Personal Data for as long as we need to, taking into account the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our recordkeeping obligations, we will retain Accounts and Personal Data for at least five years after Clients close the Accounts.
8 Links
Our Site may contain links to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. To access third-party sites or resources, you must leave our Site. We do not control such third party sites or any content contained on them, and you agree that we are in no way responsible for any of these third-party sites, and, without limitation, for their content, policies, promotions, products, services, or actions and/or any damages, losses, disruptions or problems arising from or related to these sites. We encourage you to read all policies, rules, terms, and conditions, including the privacy policy of each site you visit.
9 Marketing
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking the appropriate boxes on the forms we use to collect your Personal Data. You can exercise this right at any time by contacting us at the following email address: support@chainblocks.net
10 Changes
The policies, content, information, promotions, disclosures, disclaimers, and functions of our Site may be revised, changed, updated and/or supplemented at any time and without prior notice at the sole discretion of the company. If this Privacy Policy changes, we will take appropriate measures to notify all clients by posting a notice on our Site, and we will post the amended Privacy Policy on the Site.
11 Contact informationIf you have any questions, comments, or remarks regarding our Privacy Policy and/or company practices, please contact us at support@chainblocks.net
You have the right to withdraw funds from your Account. In order to withdraw your money from the Account, you need to make sure that your Account is verified.
Verification of your identity and Account is a requirement of the KYC (Know Your Client) policy of the Company.
You can independently withdraw funds from your Account, provided that such funds are not margin or should not be paid to us for any other reason. To withdraw funds, you must make a withdrawal request on the chainblocks.net website.
Please note that when you withdraw funds from your Account, you must pay a commission of 4% of the withdrawn amount, which is necessary to cover the commissions that Chainblocks pays to payment processors for the successful completion of the withdrawal procedure. By making a withdrawal request on the Company’s chainblocks.net website, you declare and confirm that you are aware of the commission and agree to pay 4% of the withdrawal commission.
Once approved, we will process your withdrawal request as soon as possible and send it for execution to the same bank, to the same credit card or to another source from which the funds were debited, or wherever we decide in our sole discretion.
Withdrawals are made only from accounts and cards issued in your name.
Please note that some banks and credit card companies may take time to process payments, especially when a correspondent bank is involved in the transaction.
Please be advised that if the client does not pass due diligence to the satisfaction of Chainblocks, they may experience withdrawal issues. If you make a request to withdraw funds from your account and we cannot fulfill it without closing some of your open positions, we will not fulfill the request until you have closed enough positions to be able to withdraw funds. Before making a withdrawal request, make sure that the funds, namely the realized balance on your account, after the withdrawal is completed, will be at least twice the used margin.
1 General conditions
The client who paid for the services of the company, i.e. the transaction fee, or depositor, may request a refund in accordance with the Eligibility Criteria set forth herein.
Refunds are only considered if the Client fully complies with the Eligibility Criteria. If the Client does not meet at least one of the Eligibility Criteria, the company has the right, at its sole discretion, to reject the Client’s request for a refund.
To submit a refund request, the client must complete the refund form and send the corresponding form to the company’s support service at the email address: support@chainblocks.net
In order to prevent Prohibited Activities, the company may check all payments and data related to the refund. In such a case, the company may ask the Client to submit certain documents, including, but not limited to, identification documents, a copy of the Client’s Payment Card and Invoice, and / or any other evidence that the disputed payment has been made. If the Client has not submitted the relevant documents or data within three (3) days after the company’s request or in case of doubt about the authenticity of the submitted documents, the company has the right to reject the Client’s request for a refund.
The Company shall process the Client Refund Form as soon as practicable. Response times will vary depending on the stated reasons for the request. In any case, the company must notify the Client of the results of the consideration of the request within the timeframe established here.
A refund request will only be approved or rejected after a thorough review by the company.
NOTE. Submission of the refund form does not guarantee that the Client’s request will be satisfied.
2 Operations using cryptocurrency (for example, BitCoin)
Refunds are not possible for all transactions in which the client buys cryptocurrency. However, if the client changes his mind and wants to return the purchased cryptocurrency, the company can redeem it at the current market price minus the transaction fee. In other words, the client can receive funds for the purchased cryptocurrency (for example, BitCoin) through any existing electronic system (for example, PayPal) or any payment method (for example, credit card or bank transfer).
The reason for this policy is the fact that the price of cryptocurrencies is constantly changing, so the cost of the purchased cryptocurrency at the time of the refund will be different.
3 Operations WITHOUT the use of cryptocurrencies (for example, BitCoin)
Refunds are possible within 30 days from the date of the exchange. The company will charge the client a one-time return fee of 5% of the transaction amount, as well as any additional service fees incurred when funds were sent to the client using the original payment method.
For example, if a client purchased digital currency through Money Gram money transfers and would like to receive a refund, he must send the full amount of the purchased digital currency back, and the company in return sends the money to the client through Money Gram minus the transfer fee, as a result of which the client will receive his the initial payment minus 5% (or less) of the Money Gram money transfer fee.
4 Operations for buying Amazon.net gift cards from a company
When purchasing an Amazon.net gift card on the company’s chainblocks.net website, the client must restore the balance immediately after purchase, since funds for such transactions are non-refundable.
If the client is unable to restore the balance of the card due to the limitations of their Amazon.net account, the company may consider returning the card, however, if there is no balance on the card or the balance is incomplete, the company will not be able to return the funds for this operation.
Force Majeure:
– The company is not responsible for cases where a client is unable to redeem an Amazon.net gift card due to a lack of account balance or an invalid gift card code. When the Amazon.net Gift Card Code is provided to the client, the company also provides a screenshot of the Gift Card Balance, verifying the Gift Card Balance at the time it is sent to the client.
– The company cannot be held liable for the client misusing the code or failing to ensure security on the Internet, because anyone with access to the client’s email or device can redeem the code without the client’s permission.
– Amazon.net does not provide a gift card investigation service, so the company cannot help investigate the issue.
– The company at its own discretion decides whether the client in certain cases is entitled to compensation based on the fact that he was in partnership with the company.
5 RETURN PAYMENTS
The Company expects the Client to contact it using the company’s contact information to resolve any issue or issue related to his / her payments before making any request for a chargeback. This section does not affect any rights and / or claims that the Client may bring to the bank / financial institution.
The Company will investigate any requests for chargebacks made by the Client and in response will inform the Client’s issuing bank if any service or operation has been canceled.
The Company reserves the right to suspend the Client’s account and block the Client’s funds during the procedure for investigating the return of payments.
6 MISCELLANEOUS
Any costs that arise when processing a refund request are solely borne by the Client. Such expenses will be deducted from the total refund amount.
This Refund Policy will be amended from time to time if there are any changes in legislation. The terms and conditions of the Refund Policy are subject to change by the company, and in the event of any changes, the company will make an appropriate announcement. Changes will take effect upon notification from the company.
If the Client does not wish to accept the revised Refund Policy, he/she should not continue to use the Company’s Services. If the Client continues to use the Services after the effective date of the changes, he/she must do so in accordance with the new Refund Policy.
The parties will endeavor to settle any claims or disputes arising between them from or in connection with this Agreement in good faith. If the parties cannot agree on the terms of a settlement, either party may submit the dispute to confidential arbitration by a single arbitrator. The decision of such a judge will be final and binding. The arbitration proceedings are conducted in Estonia. Without violating any of the provisions set forth above, this clause expressly establishes exclusive jurisdiction over the said arbitration process, and neither Party shall have the right to bring any dispute to the court at the place of registration if it conflicts with the specified arbitration procedure.
When registering, you will be required to provide us with certain identification information. You are responsible for the security of your company account login and password. You are solely responsible for any damage caused as a result of any action or omission that resulted in the improper or illegal use of your account.
You agree to provide accurate and complete information about yourself during the registration process, and you also agree not to impersonate another person or entity and not to hide your identity from the company for any reason. If you register as a for-profit organization, you represent that you have the necessary authority to oblige the relevant organization to comply with the terms of this Agreement.
The company is attentive to the information you provide to us in accordance with the privacy and disclosure policy provided during the registration process.
Please also note that the company maintains effective and transparent procedures for the reasonable and prompt resolution of complaints from existing and potential retail customers, and we keep a record of complaints and the steps taken to resolve them. The purpose of this procedure is to ensure that client complaints are dealt fairly and consistently while ensuring the highest level of customer service.
Your use of the Site and the Services is at your own risk. The Company is not responsible for any damage or loss of any kind that you incur as a result of changes and improvements, as well as the termination and / or suspension of the Site or any of the Services offered on the Site.
The company is not responsible for any damage or loss that you may incur as a result of using the content of any site, links to which appear on our Site. We do not control any third-party links, services, resources, and information that we provide or post on our Site. We make no warranties with respect to such third-party services, resources, and information and will not be responsible for the use of such third-party services, resources or information.
You expressly agree that your use of this site is at your own risk. We and our employees, agents, or licensors do not guarantee that this site will function smoothly or without errors; also we do not make any guarantees regarding the results that can be obtained using this site.
Termination Policy:
You or we may suspend or terminate your Account or your use of this Site at any time, for any reason or no reason. Except for the withdrawal of accumulated funds, you will not be entitled to any compensation for the termination of the provision of services in accordance with our deposit and withdrawal policy and applicable laws and regulations. We reserve the right to change, suspend or discontinue all or any section of this site at any time without prior notice.
You or we may terminate your account and services on this Site at any time, for any reason or no reason. To cancel your use of our services, please contact us.
Countries and territories
Legal Restrictions: Without limiting the provisions listed above, you understand that the laws regarding financial contracts vary around the world and are responsible for ensuring that any law, regulation, or regulation in your country of residence regarding your use of the Site is properly complied with. For the avoidance of any doubt, it should be noted that being able to access our Site does not necessarily mean that our Services and/or your activities on the Site are legal and in accordance with the laws, rules, or directives in force in your country of residence.
The Company may not provide the Services in all markets and in all countries and territories and may restrict or prohibit the use of the Services in some US states or other countries and territories (“Prohibited Countries”). If you register to use the Services on behalf of a legal entity, you represent and warrant that (a) such legal entity is properly organized and operates in accordance with the applicable laws of the country in which it was formed; (b) you are duly authorized by such entity to act on its behalf.
You also represent and warrant that:
you have reached the age of majority to enter into a binding contract (at least 18 years old);
you have never been denied or suspended your right to use our Services before;
you have all the rights and powers to enter into this agreement and do not violate any other agreements to which you are a party;
you are not in the territory, you are not a citizen, citizen or resident
any Prohibited Country or
a country that the United States has imposed an embargo on goods and services;
You are not included in the “List of citizens of special categories and prohibited persons”;
Not Listed on the United States Department of Commerce Banned Persons List;
you will not use our Services if any applicable laws in your country prohibit you from doing so in accordance with these Terms.
Prohibited countries – we cannot provide our services to residents of the following countries/states
USA
New York
Georgia
Connecticut
New Mexico
Washington
Hawaii
Afghanistan
Bosnia and Herzegovina
Cuba
Ethiopia
Iran
Iraq
Democratic People’s Republic of Korea
Lao People’s Democratic Republic
Sri Lanka
Sudan
The Syrian Arab Republic
Trinidad and Tobago
Tunisia
Uganda
Vanuatu
Yemen
Lebanon
Serbia
Algeria
Bangladesh
Bolivia
Cambodia
China
Kyrgyzstan
Macedonia
Nepal
Nigeria
Thailand
Know Your Client (KYC) is becoming increasingly important around the world, especially in banking and finance, to prevent identity theft, money laundering, financial fraud and terrorist activities. Chainblocks has a zero-tolerance fraud policy and takes all possible measures to prevent it. Any fraudulent activity will be documented and all related accounts will be closed immediately. All funds in these accounts will be lost.
Prevention:
The company strives to ensure the integrity of any confidential data received, in particular, information about your account and transactions performed, using various security measures and means of protection against fraud. Securing your electronic transactions requires that you provide us with certain information, including your preferred deposit method.
Definition of the term “client”
For the purposes of KYC policy of the Company “Client” means any of the following persons:
The person who maintains an account and / or does business with the Company;
A person who has a Registered Account with the Company who conducts financial transactions or any financial activity with the Company;
The person on whose behalf the Registered Account is maintained (i.e. the beneficial owner);
Any other person associated with financial transactions who may pose significant reputational or other risks to the Company.
The principles of cooperation with Clients in the Company as a whole include the following:
It is forbidden to open any accounts anonymously or in a non-existent name;
Clients are accepted only after confirmation of their identity. Before opening a new account, all necessary checks should be carried out so that the Client does not turn out to be a person with a known criminal history and is not associated with prohibited organizations;
Clients are classified into different risk categories and, depending on the degree of risk, appropriate acceptance criteria are applied to each client category. Clients requiring a very high level of oversight, such as Politically Exposed Persons (by definition), may, if necessary, be categorized as high risk.
Requirements for documentation and other information in relation to various categories of clients are collected depending on the perceived risk and in accordance with anti-money laundering legislation.
It is prohibited to open a new account, and it is also necessary to close an existing account in cases where the identity of the account holder cannot be verified and / or it is impossible to obtain / verify the necessary documents / information in accordance with the risk categories due to the Client’s refusal to cooperate or the unreliability of the data / information provided to the Company.
The implementation of the KYC policy shall not lead to unnecessary restrictions for the general population and the refusal of the Company’s services.
The decision to open an account for a Politically Exposed Person (PEP) must be made at the highest level. However, this may require suitable protective equipment to avoid harassing the client. For example, the decision to close an account can be made at a sufficiently high level after proper notification of the client with an explanation of the reasons for such a decision.
Under no circumstances the Client is allowed to act on behalf of another person.
Documents required in accordance with the KYC policy:
– a copy of a valid passport with a signature page, passport OR driver’s license;
– Copies of the credit cards used to make the deposit (front side with only the last 4 digits visible, your name and expiration date. Back side with closed CVV and open signature);
– A copy of a recent utility bill in your name with the specified address.
All mentioned documents must be provided prior to taking any action on the client’s account, including, but not limited to, depositing funds or making transactions.
The company considers document security as the highest priority and maintains the maximum confidentiality of all documents received. All files we receive are fully protected by using the highest possible level of encryption at every stage of the verification process.
Informing of the Clients
The Company always informs Clients about the objectives of the KYC policy for them to understand the purposes of collecting relevant information. The Company has also developed the current Terms and Conditions for this purpose in order to inform the Client about the objectives of the KYC policy.
Launching of new technologies
The company must pay particular attention to any money laundering threats that may arise from new or emerging technologies, including online transactions that may promote anonymity, and, if necessary, take measures to prevent their use for money laundering.
Closing accounts / terminating financial / business relationships
In cases where the Company is unable to apply the appropriate KYC policy measures due to lack of information and / or passivity of the Client, the Company terminates financial / business relations after proper notification of the Client with an explanation of the reasons for such a decision. This decision is made with the approval of key management personnel with the appropriate authority.
KYC policy for existing accounts
While the KYC policy will apply to all new Clients, it also applies to existing Clients on a material and risk basis. At the same time, transactions with existing Clients will be constantly monitored for any unusual activity on the account.
KYC policy update
The KYC policy can be changed / updated in accordance with current legislation and international rules.If you have any questions, please do not hesitate to contact our support team via the following email address: support@chainblocks.net
Clients of the company can withdraw their funds and earned money at any time.
To request a partial or full withdrawal from your account, click Withdrawal request on your account.
Please note that it takes us 5-7 business days to process your withdrawal request. The corresponding withdrawal will take up to 3 business days until the money reaches your credit card or bank account.
Feel free to contact our customer support specialists if you have any questions.
In accordance with generally accepted AML rules and regulations, withdrawals should only be made through the same bank account or credit / debit card that you used to deposit funds.
The company does not tolerate money laundering and supports the fight against money launderers.
Money laundering is the act of concealing the transformation of profits from illegal activities and corruption into ostensibly “legitimate” assets. Money laundering occurs when funds from an illegal/criminal activity are moved through the financial system in such a way as to make it appear that the funds have come from legitimate sources.
The first involves introducing cash into the financial system by some means (“placement”); the second involves carrying out complex financial transactions to camouflage the illegal source of the cash (“layering”); and finally, acquiring wealth generated from the transactions of the illicit funds (“integration”). Some of these steps may be omitted, depending upon the circumstances. For example, non-cash proceeds that are already in the financial system would not need to be placed.
Typically, money laundering involves three steps:
- placement;
- layering;
- integration.
First, the illegitimate funds are furtively introduced into the legitimate financial system. Then, the money is moved around to create confusion, sometimes by wiring or transferring through numerous accounts. Finally, it is integrated into the financial system through additional transactions until the funds become legitimate.
Customer accounts are one vehicle that can be used to launder illicit funds or to hide the true owner of the funds. In particular, a customer account can be used to execute financial transactions that help obscure the origins of the funds. The company directs funds withdrawals back to the original source of remittance, as a preventative measure.
International Anti-Money Laundering requires financial services institutions to be aware of potential money laundering abuses that could occur in a customer account and implement a compliance program to deter, detect and report potential suspicious activity.
The company has policies in the field of counteraction of laundering money. These policies include:
- ensuring clients have valid proof of identification;
- requiring the client to provide valid utility bills for proof of residence;
- maintaining records of identification information;
- determining that clients are not offenders or terrorists by checking special lists;
- informing clients that the information they provide may be used to verify their identity;
- closely following clients’ money transactions;
- maintaining records of identification information.
- not accepting money orders, third party transactions, exchange houses transfers or Western Union transfers.
- The AML measures which the Company generally will take
- collect sufficient information from each Customer who has opened an account to enable the Customer to be identified;
- utilize risk-based measures to verify the identity of each Customer who has opened an account;
- record Customers’ information and the verification methods and results; provide the required adequate notice to Customers that we will seek identification information to verify their identities;
- compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.
Monitoring of Transactions
Ongoing monitoring is an essential element of effective KYC procedures. Monitoring of transactions and its extent will be conducted taking into consideration the risk profile and risk sensitivity of the account. Company shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose. Company may prescribe threshold limits for a particular category of accounts and pay particular attention to the transactions which exceed these limits. Transactions that involve large amounts of cash inconsistent with the normal and expected activity of the customer should particularly attract the attention of the Company.
Higher risk accounts shall be subjected to intense monitoring. Company shall set key indicators for such accounts basis the background of the customer, country of origin, sources of funds, the type of transactions involved and other risk factors which shall determine the extent of monitoring. Company shall carry out the periodic review of risk categorization of transactions/customer’s accounts and the need for applying enhanced due diligence measures at a periodicity of not less than once in six months.
Risk Management
The Management of the Company under the supervision of the Board of Directors and the Risk Committee shall ensure that an effective KYC program is put in place by establishing appropriate procedures and ensuring their effective implementation. It will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility will be explicitly allocated within the Company for ensuring that the policies and procedures as applicable to Company are implemented effectively. The Company shall devise procedures for creating Risk
Profiles of their existing and new Customers and apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship.
Broad categories of reason for suspicion and examples of suspicious transactions are indicated as under:
Identity of client:
a) False identification documents
b) Identification documents which could not be verified within a reasonable time
c) Accounts opened with names very close to other established business entities.
Background of Client: suspicious background or links with known criminals.
Multiple Accounts: a large number of accounts having a common account holder.
Activity in accounts:
a) Unusual activity compared with past transactions
b) Sudden activity in dormant accounts;
Nature of transactions;
a) Unusual or unjustified complexity;
b) No economic rationale or bonafide purpose;
c) Nature of transactions inconsistent with what would be expected from a particular Customer.
These guidelines have been implemented to protect the company and its clients.