CARDTONIC’s Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of CARDTONIC being involved in any kind of illegal activity.

Both international and local regulations require CARDTONIC to implement effective internal procedures and mechanisms to prevent Money laundering, Terrorism financing, Narcotics and Human trafficking, Proliferation of weapons, Corruption and Bribery; and to take action in case of any form of suspicious activity from its Users.

Our AML/KYC Policy covers the following matters:

1. Verification procedures.

2. Compliance Officer.

3. Monitoring Transactions.

4. Risk Assessment.

 

Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). Consequently, CARDTONIC establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

 

Identity verification

CARDTONIC's identity verification procedure requires the user to provide us with reliable, independent source documents, data or information (e.g., National ID, International passport, Voter's Card, Bank statement, Utility bill). For such purposes, CARDTONIC reserves the right to collect users’ identification information for the AML/KYC Policy purposes.

CARDTONIC will take steps to confirm the authenticity of documents and information provided by the users. All legal methods for double-checking identification information will be used and CARDTONIC reserves the right to investigate certain users who have been determined to be risky or suspicious.

CARDTONIC reserves the right to verify users' identity on an on-going basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular user). In addition, CARDTONIC reserves the right to request up-to-date documents from the users, irrespective of if they previously fulfilled identity verification requirements.

Users' identification information will be collected, stored, shared and protected strictly in accordance with CARDTONIC's Privacy Policy and similar regulations.

Once the user’s identity has been verified, CARDTONIC is able to absolve itself of potential legal liability in a situation where its Services are used to conduct illegal activity.

 

Card verification

Users who intend to use payment cards in connection with the CARDTONIC's Services have to pass card verification in accordance with instructions available on the CARDTONIC site.

 

Compliance Officer

The Compliance Officer is the person, duly authorized by CARDTONIC with the duty of ensuring the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of CARDTONIC'S anti-money laundering and counter-terrorist financing, including but not limited to:

  1. Collecting Users’ identification information. 
  2. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. 
  3. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. 
  4. Updating risk assessment regularly. 
  5. Providing law enforcement with information as required under the applicable laws and regulations.

 

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing and other illegal activity.

 

Monitoring Transactions

Users are known not only by verifying their identity but also by analyzing their transactional patterns (what they do). Therefore, CARDTONIC relies on data analysis as a risk-assessment and suspicion detection tool. CARDTONIC performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting. System functionalities include:

  1. A regular check of Users against recognized “blacklists” (e.g Law enforcement Notices), placing users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  2. Case and document management.
  3. With regard to the AML/KYC Policy, CARDTONIC will monitor all transactions and it reserves the right to:
  4. Ensure that transactions of suspicious nature are reported to the proper law enforcement agencies;
  5. Request the User to provide any additional information and documents in case of suspicious transactions;
  6. Suspend or terminate a user’s Account when CARDTONIC has reasonable suspicion that such user engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

 

Risk Assessment

CARDTONIC, in line with the global requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, CARDTONIC is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

 

Last Updated 25th Of December, 2019.

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