KYC & AML Policy

Pii Fund e-Wallet KYC / AML Policy

 

In terms of law, money laundering means legalizing the proceeds of crime, i.e. actions that conceal the source of funds in order to make their nature lawful.

Anti-money laundering (AML) incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business communities. That is why national and international laws make it illegal for Pii and its employees to be knowingly or recklessly engaged in any activity related to such illegally gained capital.

 

Implemented Procedures

Pii implements a strong anti-laundering policy to ensure that its customers will be identified for such suspicions up to a certain standard to minimize the procedural complications for genuine and legitimate customers. In order to fulfil its commitment to provide full assistance to governments combating such illegal financial transactions, Pii has developed a technologically advanced and reliable electronic system, which completely verifies its client identity and is able to maintain a detailed record of all previous financial transactions.

 

Pii makes sure to track all suspicious activities and report any of these to the relevant law enforcement bodies. That is why complete legal protection is provided to clients who share confidential financial data with the company.

 

To discourage money laundering and related illegal activities, Pii does not deal in cash transactions whether to deposit or withdraw funds. Our company reserves the right to suspend any transaction where it finds even a suspicion of money laundering.

 

Pii collects identification data of every Client, as well as IP addresses, online activity, communications and, in general, all transactions carried out by the Client.

 

Pii tracks, including auto-monitoring and auto-controlling, suspicious activities of the clients and transactions executed under unusual conditions. These include, but are not limited to, transactions that do not make economic sense, unexplained large transactions, transactions involving unidentified parties, investments related transactions of unclear nature. Pii reserves the right to ask for supporting documentation for the suspicious transactions.

 

Users must notify Pii in case they identify any unauthorized transactions in their account. Enhanced Due Diligence is exercised on high-risk customers, high turnover customers and/or potential suspicious customers/transactions. The purpose of the transaction is established where applicable.

 

Pii improves its AML procedures continuously to monitor unlawful financial schemes.

 

Pii reserves the right to refuse to process a transaction at any stage, when we believe that the transaction is associated with money laundering or other criminal activity.

 

Pii complies with the legal requirements of the United States for anti-money laundering. In cases set forth in the relevant legal enactments, we cooperate with officials and government institutions of the United States, as well as other countries.

 

Non-acceptable use Policy Pii has also an established non-acceptable use policy which clearly states the business models that will not be acceptable. Those include, but are not limited to:

 

  • Material which incites or promote violence and/or racism
  • Prescription drugs, illegal drugs
  • Illegal tobacco products
  • Firearms and weapons
  • Pornography, child pornography, adult material
  • Satellite and cable TV descramblers
  • Any fake or counterfeit government ID, Visa, Driver License or other identification
  • Any goods or services that infringe on the intellectual property rights of third parties
  • Pyramid or Ponzi scheme products or third-party payment processing or payment aggregation products, multi-level marketing and other “get-rich-quick” schemes or high yield investment programs
  • Prepaid or other stored value cards that are not associated with a merchant and/or are not limited to purchases of particular products or services
  • Unlicensed gambling services of any type
  • Non-acceptable customers/individuals
  • The Company will not establish a Business Relationship with customers / groups of customers that present unacceptably high risks. Customers whose acceptance must be refused, if they are natural persons or legal entities, must meet one or more of the following criteria:

 

  • Reside in countries considered sanctioned countries
  • The intended purpose of use of the account is defined as “Non-Acceptable”
  • Are included in National or Supra-National Sanctions lists as “Sanctioned person or entity”
  • There is available public information about involvement or investigation for drug manufacturing, drug trafficking, people smuggling, sexual servitude, illegal logging / phishing, fraud or organized theft, corruption
  • Fail or refuse to provide the Company with requested information or documents
  • Provide false or misleading information

 

Compliance Department

Like other financial institutions, Pii has also set up a compliance department in order to fulfil its formal legal requirements. This includes the appointment of a Compliance Officer, policy making, regular review of their implementation and impact and professional compliance training to staff members. Pii also ensures regular updating of its electronic systems to modern rules and regulations developed for more sophisticated checks to trace money laundering and other criminal financial practices. Professional training is provided to Pii’s employees to trace such illegal activities and to use modern technological systems, which constitutes part of Pii’s essential policies.

 

Additional Disclosure

Identification

In order to fully comply with anti-money laundering laws, Pii demands, at a minimum, two forms of documents for the satisfactory identification and verification of customers’ accounts. The first one is a government issued document with a photo of the customer on it. It can be a passport, driving license or State ID which must be issued by the government. The second one is any utility bill, bank statement or government-issued document with the complete name and address information on it. The proof of address must be issued within the last three months from the application date. On a case by case basis, Pii may require additional documentation from its clients in order to comply with the due diligence process, which may vary for customers from country to country. Customers are also required to inform Pii if there are any changes to their personal information. In case documents are in a non-western.

 

Deposits and Withdrawals

In case of money deposits via wire, ACH, third party eWallet, the sender’s name must match the name of the customer present in Pii’s record. Similarly, in case of a money withdrawal, the recipient’s name must match the name of the account holder they are withdrawing money from. If the transaction is online money, then funds will only be withdrawn through the same online transfer system to the same account from where it has been transferred.

 

The Pii Wallet has established a Know Your Customer (KYC) and Anti Money Laundering (AML) policies to to mitigate the risk of the firm being used to facilitate financial crimes. These procedures allow us to positively identify every retail consumer that onboards with Pii Fund, understand the legitimacy of their business relationship, and to identify unusual or suspicious activity. 

In support of our KYC policy and procedures, Pii Fund has integrated with a third party KYC provider named Plaid to collect all the necessary information to identify users, risks, and bank accounts needed to open an e-wallet account. 

This KYC\AML Policy sets out the minimum standards that must be complied with and includes:

  • The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employee
  • In accordance with proper AML procedures, the following documents must be provided by each client:
  • Copy of ID (government issued / driver’s licence)
  • Proof of address (e.g. cable bill, water bill, bank statement)

 

Definitions:

AML – Anti-Money Laundering – Set of procedures, laws or regulations designed to stop the practice of generating income through illegal actions.

Title 31 – Federal law designed to identify and prevent money laundering and tax evasion. Also known as the Bank Secrecy Act. Key requirements of Title 31 are:

  • Track and report cash
  • Identify and report suspicious activity

BSA – Bank Secrecy Act was enacted by Congress in 1970. Also known as Title 31. Assists in the detection of illegal activity to discourage the laundering of illegally gotten monies.

CryptoCurrency – A digital currency which is an alternative form of payment created using encryption algorithms. To use cryptocurrencies, you’ll need an ewallet.

CTR – Currency Transaction Report – a report that is required to be filed with FinCEN for currency of more than $10,000.

e-Wallet – An e-Wallet is a secure money management app or online platform that allows you to make purchases with retailers at point of sale (POS), transfer or send money peer to peer (P2P).

FinCEN – Financial Crimes Enforcement Network was established by Congress to provide a government-wide multisource financial intelligence and analysis network, including regulatory responsibilities for administering the Bank Secrecy Act.

KYC – Know Your Customer is a form of guidelines in financial services that require the Firm to make an effort to verify the identity, suitability, and risk involved with maintaining a business relationship. 

Money Laundering – Method used by individuals to make illegally gained or untaxed money to appear legitimate.

MIL or NIL – Monetary Instrument Log or Negotiable Instrument Log – used to track individual monetary instruments with a face value of $3,000 or more.

SAR – Suspicious Activity Report – a report required to be filed with FinCEN in which there is a reason to suspect the transaction or attempted transaction is related to a money laundering offence or a terrorist activity financing offence.

FATF – Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.

MSB – money services business (MSB) is a legal term used by financial regulators to describe businesses that transmit or convert money. The definition was created to encompass more than just banks which normally provide these services to include non-bank financial institutions.

Money Transmitters – a money transmitter or money transfer service is a business entity that provides money transfer services or payment instruments. Money Transmitters in the US are part of a larger group of entities called Money Service Businesses or MSBs.

NBFI – Non-bank financial institution is a financial institution that does not have a full banking license or is not supervised by a national or international banking regulatory agency. NBFIs facilitate bank-related financial services, such as investment, risk pooling, contractual savings, and market brokering.

FI – Financial institution is an establishment that conducts financial transactions such as investments, loans and deposits.

Fiat Money – Fiat money is a currency established as money by government regulation or law.

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