Date:2019-10-01 03:22:49

Anti-money Laundering and Know Your Customer Policy

The purpose of the Needyex Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is to identify, prevent and mitigate possible risks of Needyex being involved in illegal activity.

In conformity with international and local regulations Needyex has implemented effective internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users.

AML/KYC Policy includes Verification procedures, Compliance Officer, Monitoring Transactions, Risk Assessment. Customer due diligence (“CDD”) has become one of one of the international standards for preventing illegal activity. Thus, Needyex has implemented its own verification procedures within the rigorous standards of anti-money laundering and “Know Your Customer” procedures.

The Needyex identification procedure requires the User to provide Needyex with reliable, independent source documents, data or information (for example, a national ID card, an international passport, an extract from the bank, a utility bill). For such purposes, Needyex reserves the right to collect the User’s identification information for the purposes of AML / KYC Policy compliance.

Needyex will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used, and Needyex reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious.

Needyex reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, Needyex reserves the right to request from the Users current documents, even if they have been authenticated in the past.

Information about the user’s identification will be collected, stored, shared and protected strictly in accordance with the Needyex Privacy Policy and relevant rules.

After confirming the identity of the user, Needyex may refuse potential legal liability in a situation where the company’s services are used to conduct illegal activities.

The Compliance Officer is the person, duly authorized by Needyex, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Needyex’s anti-money laundering and counter-terrorist financing, in particular collecting Users’ identification information, 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, monitoring transactions and investigating any significant deviations from normal activity, implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs, updating risk assessment regularly, providing law enforcement with information as required under the applicable laws and regulations.

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

The Users are known not only by verifying their identity by analyzing their transactional patterns. Therefore, Needyex relies on data analysis as a risk-assessment and suspicion detection tool.

Needyex performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include: Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable; Case and document management. In connection with the AML/KYC Policy, Needyex will monitor all transactions and it reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; request the User to provide any additional information and documents in case of suspicious transactions; suspend or terminate User’s Account when Needyex has suspicion that such User engaged in illegal activity.

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

Needyex, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Needyex is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks