AML / KYC Policy

Effective Date: 9.09.2024

Introduction

Poliada Ecosystem is firmly committed to upholding the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance in accordance with applicable local laws, international regulations, and industry best practices. We utilize multiple tools to identify and mitigate potential risks, including but not limited to:

Chainalysis for real-time blockchain transaction analysis and risk scoring.
DiliSense AML Screening API (based in Switzerland) for additional checks on sanctions lists, Politically Exposed Persons (PEPs), and other high-risk indicators.
OpenSanctions.org (based in Germany) to cross-reference global sanctions lists, watchlists, and PEP databases.

If any transaction is identified as high-risk through these tools, Poliada Ecosystem reserves the right to block or freeze the transaction and initiate a formal review with the appropriate regulatory or law enforcement authorities. We also perform KYC assessments to evaluate potential investment amounts, risk levels, and user profiles. For higher-risk cases, we conduct manual Enhanced Due Diligence (EDD), requesting additional Source of Funds (SOF) documentation and applying rigorous AML procedures.

This AML/KYC Policy applies exclusively to individuals investing in Poliada Ecosystem’s crypto-economy products or offerings. It outlines our measures to deter illicit activities such as money laundering, terrorist financing, and other financial crimes. Regular (non-investor) users may not be subject to these strict AML/KYC requirements.

Section 1: Scope and Purpose

1.1 Scope

This policy applies to all individuals who invest in Poliada Ecosystem’s crypto-economy projects. It covers:

Investor Identification and Verification: Implementing procedures to verify the identity of all investors, in line with applicable AML and KYC regulations.
Risk-Based Management: Managing risks associated with investors from jurisdictions or backgrounds identified as high-risk or under increased monitoring.
Source of Funds (SOF) Verification: Verifying the legitimacy of funds for higher-value investments (e.g., equal to or exceeding 15,000 USD or equivalent in other currencies), as recommended by international AML standards.
Transaction Monitoring: Utilizing Chainalysis and other compliance tools to screen and monitor all investments, regardless of amount, to effectively assess and manage risk.

1.2 Purpose

The purpose of this policy is to:

Ensure Legal and Regulatory Compliance: Adhere to all relevant local and international laws and guidelines on preventing money laundering and terrorist financing.
Prevent Illicit Activities: Detect and deter money laundering, terrorist financing, fraud, and other financial crimes.
Mitigate Risks: Identify, assess, and mitigate risks associated with high-risk jurisdictions, large transactions, and suspicious activities.
Maintain Transparency and Accountability: Ensure transparency in all investment processes, keeping clear records and reporting as required.
Protect Stakeholders: Safeguard the interests of Poliada Ecosystem, its investors, and the broader financial community by implementing robust AML/KYC measures.

Section 2: Country-Based Restrictions and Risk Management for Investors

2.1 Prohibited Jurisdictions (High-Risk and Sanctioned Countries)

Poliada Ecosystem strictly prohibits investments from individuals located in countries or territories that are subject to international sanctions or identified as high-risk by recognized bodies such as the Financial Action Task Force (FATF) or the United Nations (UN). This prohibition helps reduce the risk of money laundering, terrorist financing, or other illicit activities.

Examples of Prohibited Countries/Territories may include, but are not limited to:

North Korea
Iran
Crimea Region
Any jurisdiction under comprehensive international sanctions

Rationale for Prohibition:

Legal Compliance: Adhering to international sanctions and relevant regulations to avoid facilitating illegal activities.
Risk Mitigation: Reducing the possibility of money laundering and terrorist financing by excluding high-risk or sanctioned jurisdictions.

2.2 Restricted Jurisdictions (Jurisdictions Under Increased Monitoring)

Certain jurisdictions may be designated by the Financial Action Task Force (FATF) or other recognized bodies as having strategic AML/CFT deficiencies but making efforts to address them. These are sometimes referred to as "grey list" countries. Although not completely prohibited, investors from these areas may be subject to closer scrutiny due to the heightened risk they pose.

Examples of Restricted Countries (Subject to Change Based on FATF Updates):

Albania
Barbados
Burkina Faso
Cambodia
Cayman Islands
Haiti
Jamaica
Jordan
Mali
Morocco
Myanmar
Nicaragua
Pakistan
Philippines
Senegal
South Sudan
Uganda
Yemen
Zimbabwe

Policy for Restricted Jurisdictions:

Enhanced Due Diligence (EDD): Investors from these jurisdictions are required to undergo EDD, which may include additional documentation requests (e.g., detailed Source of Funds) and more comprehensive identity verification.
Ongoing Monitoring: All transactions from these investors are closely tracked using Chainalysis for blockchain analysis, along with DiliSense AML Screening API and OpenSanctions.org for broader checks on sanctions and PEP lists.
Periodic Review: Poliada Ecosystem frequently reviews the FATF’s publications and other credible sources to update our list of restricted jurisdictions. Any newly identified regions may be added to the restricted list, and existing investors from these regions may be subject to re-evaluation.
Management Approval: Investments originating from these areas often require additional compliance checks and approval from senior management before proceeding.

2.3 Risk Assessment and Management

Poliada Ecosystem adopts a risk-based approach aligned with international AML standards. We use various tools—such as Chainalysis, DiliSense AML Screening API, and OpenSanctions.org—to monitor both transactional activity and investor status (e.g., identifying PEPs or sanctioned entities). This approach ensures proactive identification and mitigation of potential risks.

Customer Risk Profiling:

Low Risk: Investors from regions with transparent AML/CFT frameworks.
Medium Risk: Investors from countries with partial but not fully robust AML/CFT measures.
High Risk: Investors from restricted jurisdictions or those associated with inherently high-risk activities.

Transaction Monitoring:

Automated Monitoring: Utilizing Chainalysis to track all transactions for suspicious patterns.
Manual Review: Compliance officers review alerts flagged by the automated system, referencing additional databases (e.g., DiliSense AML Screening API or OpenSanctions.org) to verify potential sanctions or PEP matches.

Ongoing Due Diligence:

Regularly updating investor information and re-evaluating risk profiles.
Monitoring for changes in investor status, such as becoming a Politically Exposed Person (PEP) or appearing on sanctions lists.

2.4 High-Risk Activities and Industries

Investments from individuals involved in certain high-risk activities or industries may be subject to additional scrutiny or may be outright prohibited. Examples include:

Arms and Weapons Trade
Precious Metals and Stones Dealers
Money Service Businesses (MSBs)
Shell Companies

Policy for High-Risk Activities:

Enhanced Due Diligence: Collecting detailed SOF and Source of Wealth (SOW) information.
Senior Management Approval: Required prior to accepting investments from these sectors.
Ongoing Monitoring: Heightened scrutiny of all transactions and periodic reviews.

2.5 Politically Exposed Persons (PEPs)

Investors identified as Politically Exposed Persons (PEPs), or their immediate family and close associates, are subject to Enhanced Due Diligence measures.

Definition of PEPs:

Individuals who hold or have held prominent public functions, including but not limited to:

Heads of State or Government
Senior Politicians
Senior Government, Judicial, or Military Officials
Senior Executives of State-Owned Enterprises
Key Political Party Officials

EDD Measures for PEPs:

Enhanced Identity Verification: Using multiple independent sources to confirm identity.
SOF and SOW Verification: Documenting the legitimate origin of funds and overall wealth.
Senior Management Approval: Required before onboarding or continuing a relationship.
Enhanced Monitoring: More frequent and detailed reviews of all transactions.

2.6 Sanctions and Watchlists Screening

Poliada Ecosystem screens investors against relevant global sanctions lists and watchlists maintained by recognized international authorities (e.g., UN, OFAC, FATF).

Policy for Matches on Sanctions Lists:

Immediate Freeze: Suspend the transaction or investment process pending investigation.
Internal Review: Compliance specialists analyze the match to confirm authenticity.
Reporting: If confirmed, notify the relevant regulator or law enforcement agency.
No Notification to Investor: As required by many legal frameworks, the investor is not informed about ongoing investigations to avoid “tipping off.”

2.7 Actions upon Identification of High-Risk or Prohibited Investors

Refusal of Service: Poliada Ecosystem reserves the right to refuse service to any investor who:

Fails to meet AML/KYC requirements.
Is identified as prohibited under this policy.
Provides false or misleading information.

Termination of Business Relationship: Existing relationships may be terminated if the investor is later deemed high-risk or prohibited.

Reporting Obligations:

Suspicious Activity Reports (SARs): Filed with relevant authorities when suspicious activity is detected.
Cooperation with Authorities: We will fully cooperate with authorized investigations.

2.8 Record-Keeping

Documentation: Poliada Ecosystem maintains records of all checks, decisions, and actions related to high-risk or prohibited investors.
Retention Period: Records are retained for a minimum period (e.g., eight years) following the termination of the business relationship, in line with international best practices.

Section 3: Investor Due Diligence (IDD)

Poliada Ecosystem ensures that all investors comply with our AML/KYC requirements. By investing, you agree to follow these procedures, which are intended to verify identity and assess any associated risks.

3.1 Standard Due Diligence Procedures

We implement thorough procedures to verify your identity and evaluate potential risks, in line with global AML/KYC guidelines.

3.1.1 Identification and Verification of Private Investors

Required Information:

Full Name
Date and Place of Birth
Nationality
Residential Address
Contact Details (phone number and email address)

Required Documentation:

Proof of Identity: Valid government-issued photo ID (e.g., passport, national ID card).

3.1.2 Understanding Your Investor Profile

To establish a clear understanding of your background and investment objectives, Poliada Ecosystem:

Assesses the Purpose and Intended Nature of the Investment: Gathers information about your goals and expected level of activity.
Evaluates Source of Funds and Wealth: May request documentation to verify that investment funds come from legitimate sources.

3.1.3 Verification Methods

We employ various methods to verify documentation and information you provide:

Document Verification: Examination of original documents or certified copies for authenticity.
Electronic Verification: Use of secure electronic databases and tools, where appropriate.

3.2 Enhanced Due Diligence (EDD)

If there is a higher risk of money laundering or terrorist financing, we apply additional measures, including but not limited to:

Investors from High-Risk or Restricted Jurisdictions
Politically Exposed Persons (PEPs)
Unusual or Large Transactions

3.2.1 EDD Measures for High-Risk Investors

Additional Identification Information: More documentation to conclusively verify identity.
Source of Funds Verification: Detailed evidence of the origin of funds.
Senior Management Approval: Prior to establishing or continuing a relationship.
Enhanced Monitoring: Frequent reviews of all transactions.

3.3 Ongoing Monitoring and Due Diligence

Transaction Monitoring: Continuous checks using Chainalysis and other tools for irregularities or red flags.
Periodic Reviews: Regularly updating investor data and risk assessments.

3.4 Record-Keeping and Data Protection

Documentation Retention: We keep AML/KYC records for a specified minimum period (e.g., eight years) after the relationship ends.
Data Security: We protect personal data against unauthorized access, and only authorized staff can view such records.

3.5 Refusal or Termination of Business Relationship

Poliada Ecosystem reserves the right to decline or end a business relationship if:

You fail to meet IDD/EDD requirements.
You provide false or misleading information.
You are found to be high-risk or from a prohibited jurisdiction.
Suspicious activity is detected without a satisfactory explanation.

3.6 Reporting Obligations

Suspicious Activity Reports (SARs): Submitted to the relevant regulatory or law enforcement authority upon detection of suspicious activity.
Confidentiality: We do not disclose SAR submissions to the investor or any unauthorized party, per legal requirements.

Section 4: Source of Funds (SOF) Verification for High-Value Investments

Poliada Ecosystem requires additional verification for investments equal to or exceeding the threshold of 15,000 USD (or equivalent in other currencies). This threshold may be adjusted according to applicable laws or industry best practices.

4.1 SOF Verification Requirements

If your total investment meets or surpasses the specified amount—whether in a single transaction or multiple linked transactions—you must provide supporting evidence of the legal origin of your funds.

4.1.1 Acceptable Documentation

Bank Statements: Showing account details and recent transactions.
Payslips or Employment Records: Confirming regular income.
Tax Returns: Official documents indicating declared income.
Sale of Assets: Proof of property or investment sales.
Inheritance Documents: Legal proof of inherited funds.
Gift Letters: Explaining the nature and origin of any gifted funds.
Other Relevant Financial Documents: Any documentation confirming the legitimate source of funds.

4.1.2 Submission Process

Secure Upload: A secure portal or method is provided to ensure confidentiality.
Timely Provision: Documents must be submitted promptly to avoid delays.

4.2 Purpose of SOF Verification

Compliance: Meet AML/KYC obligations under applicable laws and international standards.
Integrity: Maintain a transparent ecosystem where all funds are legitimate.
Risk Management: Protect against illicit financial activities and ensure stakeholder trust.

4.3 Confidentiality and Data Protection

Data Security: All documentation is handled with strict confidentiality and protected from unauthorized access.
Limited Access: Only authorized compliance personnel can review SOF documents.

4.4 Failure to Provide SOF Documentation

Investment Delay: Processing may be put on hold until the requested documents are received.
Refusal of Service: We may decline or terminate the investment relationship if adequate SOF proof is not provided.

4.5 Ongoing Monitoring

Transaction Pattern Changes: If significant changes in transaction behavior occur, additional information may be required.
Regulatory Updates: New laws or industry practices may necessitate further checks.
Suspicious Activity: Unusual or potentially illicit activity may trigger further investigation.

Section 5: Transaction Monitoring and Suspicious Activity Reporting (SAR)

Poliada Ecosystem maintains vigilant oversight of all investor transactions to identify and report potential money laundering, terrorist financing, or other financial crimes. Our processes combine automated and manual reviews guided by industry best practices and relevant legal requirements.

5.1 Transaction Monitoring

Automated Monitoring with Chainalysis:

Real-Time Analysis: We use Chainalysis to monitor cryptocurrency transactions continuously.
Risk Scoring: Transactions receive a risk score based on volume, patterns, and potential links to illicit activity.
Alert Generation: The system flags higher-risk transactions for further compliance review.

5.2 Identification of Suspicious Activities

Unusual Transaction Patterns: Large or frequent transactions that do not align with known investor profiles.
Structured Transactions: Multiple smaller transactions potentially aiming to evade detection.
High-Risk Sources: Involvement of addresses or entities linked to illicit activities.
Refusal to Provide Information: Reluctance or refusal to supply required KYC/AML documentation.

5.3 Reporting Suspicious Activities

Internal Escalation: Compliance officers escalate flagged activities to senior management.
Suspicious Activity Reports (SARs): If warranted, we file a report with the relevant financial intelligence unit or regulatory authority.
Account Actions: High-risk accounts or transactions may be frozen or terminated pending further investigation.

5.4 Legal Obligations and Compliance

Our monitoring and reporting processes are designed to comply with applicable local and international AML/CFT standards.

Law Enforcement Cooperation: We cooperate fully with authorized governmental and regulatory inquiries.
Non-Disclosure: We do not inform individuals about ongoing AML investigations if prohibited by law.

5.5 Your Responsibilities

Accurate Information: Provide truthful, up-to-date details about your identity and investment intentions.
Prompt Updates: Inform us of any significant changes to your personal or financial circumstances.
Cooperation: Comply with any reasonable requests for documentation or clarification.

5.6 Data Protection and Confidentiality

Secure Handling: All transactional and personal data is securely stored and accessible only to authorized staff.
Privacy Compliance: We adhere to recognized data protection standards and respect your privacy rights.

Section 6: Data Protection and Privacy

Poliada Ecosystem is committed to safeguarding your personal data in accordance with applicable data protection laws and internationally recognized privacy standards. We handle your information responsibly and transparently.

6.1 Data Collection and Use

Types of Data Collected:

Identification Information (name, date of birth, nationality)
Contact Details (address, email, phone)
Financial Information (investment amounts, transaction history)
Verification Documents (IDs, proof of address, bank statements)

Purpose of Data Processing:

Compliance: Fulfill AML/KYC requirements.
Service Provision: Facilitate your investments and maintain our relationship.
Security: Detect and prevent fraud or other unlawful activities.
Communication: Notify you about policy updates, changes, or important information.

6.2 Data Security Measures

Technical Measures:

Encryption at rest and in transit
Secure servers with firewalls
Access controls and periodic security audits

Organizational Measures:

Staff training on data protection
Clear policies on data handling and incident response
Contractual safeguards with third-party service providers

6.3 Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with any legal or regulatory requirements.

Retention Period: AML/KYC records are generally kept for a minimum of eight years (or as required by applicable law) after the end of the business relationship.
Secure Disposal: Data is securely erased or anonymized after the retention period, unless otherwise required.

6.4 Your Rights

Depending on the data protection laws in your jurisdiction, you may have certain rights, such as:

Access: Request a copy of personal data we hold about you.
Rectification: Request corrections to inaccuracies.
Erasure: Request deletion of data under specific conditions.
Restriction: Limit how we process your data.
Portability: Obtain your data in a structured format.
Objection: Object to data processing in certain scenarios.

6.5 Contact and Exercise of Rights

For any questions or to exercise your rights, please contact our compliance or data protection team:

Email: [email protected]

We will respond to valid inquiries within a reasonable timeframe, per applicable regulations.

Service Providers: Some data may be shared with third-party providers (e.g., Chainalysis) who assist us under strict confidentiality obligations.
Legal Obligations: We may disclose data to regulators or law enforcement if legally mandated.
Business Transactions: In the event of a merger or acquisition, data may be transferred to new ownership under confidentiality agreements.

6.7 International Data Transfers

Your data may be processed in countries outside your jurisdiction. In such cases, we implement appropriate safeguards (e.g., contractual clauses) to ensure adequate protection.

6.8 Cookies and Website Data

Our website may use cookies or similar technologies to enhance user experience. For more details, please see our Cookie Policy.

Section 7: Policy Updates and Contact Information

7.1 Policy Review and Updates

Poliada Ecosystem regularly reviews this AML/KYC Policy and updates it to reflect:

Changes in Laws or Regulations
Industry Best Practices
Feedback from Investors and Internal Audits

7.1.1 Notification of Changes

Communication: Significant updates are posted on our website or shared via email.
Effective Date: The revised policy’s effective date will be indicated at the top of the document.
Continued Use: By continuing to invest or use our services, you accept any policy changes.

7.2 Investor Acknowledgment and Agreement

Acceptance: During registration or investment onboarding, you must confirm that you have read and agree to this policy.
Obligation to Comply: You agree to provide accurate data and comply with all AML/KYC requests.
Legal Implications: Non-compliance can result in the suspension or termination of your account and possible legal consequences.

7.3 Contact Information

If you have any questions or concerns about this AML/KYC Policy or related matters, please contact:

Email: [email protected]

7.4 Complaint and Dispute Resolution

Filing a Complaint: Send a detailed description of your issue to our compliance team via email.
Response Time: We acknowledge receipt within five business days and aim to resolve within one month.
Escalation: If unsatisfied, you may seek further review from relevant local authorities.

7.5 Governing Law and Jurisdiction

This AML/KYC Policy is governed by and construed in accordance with the applicable laws of the jurisdiction where Poliada Ecosystem operates. Any disputes related to this policy will be subject to the exclusive jurisdiction of the competent courts in that jurisdiction.