CALMSWAP S.R.O. AML POLICY FOR THE WEBSITE

 

Calmswap s.r.o., ID: 21246823, registered office address at Czech Republic, Cimburkova 916/8, 130 00 Prague – Žižkov, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 398874, hereinafter the ‘Company’, also ‘we’, or ‘us’.

 

We are authorised by the Ministry of Industry and Trade of the Czech Republic to provide services related to virtual assets. Within the granted authorisation we provide to our customers virtual currency exchange services.

 

While establishing business relationships with our customers and rendering our services, we always seek to disrupt money laundering, terrorism financing and proliferation financing (‘ML, TF, PF’). 

 

To prevent money laundering, terrorism financing and proliferation financing we have developed and successfully implemented robust internal AML/CTF/CPF rules and procedures in strict compliance with domestic and supra national regulatory requirements and respecting high ethical standards in the financial market. 

 

Our staff is highly skilled and sufficiently trained to detect any suspicious activity at an early stage. 

 

The main goal the Company is aimed is to minimise all possible risks and actively prevent ML/TF/PF by complying with all applicable requirements under: 

• Act No. 253/2008 Coll. 
• Act No. 69/2006 Coll. on the Implementation of International Sanctions.
• Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and amending Directives 2009/138/EC and 2013/36/EU. 
• Regulation (EU) No 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006.
• Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.

 

We do not offer any occasional transactions. Every customer is identified and verified before establishing business relationships. 

 

We establish business relationships and provide our services only to the customers, who have completely passed Know Your Customer (‘KYC’) procedure.

 

For KYC purposes each customer – private individual, should provide us at least:

• passport or ID Card (only for EEA, UK countries and Switzerland citizens), Resident permit (additional identification document), Driving licence (only for UK citizens);
• recent address confirmation document (for the last 3 (three) months);
• facial image check and comparison with identification document by automatic identification software - Sum and Substance.

 

 

 

For KYC purposes each customer – legal entity, should provide us at least:

• Incorporation, constitution and status confirmation documents;
• authorised legal entity official(s) and Beneficial Owner identification documents;
• Beneficial Owners experience and source of funds (and wealth) confirmation documents (if applicable);
• authorised official facial image check and comparing with identification document by automatic identification software – Shufti Pro;
• authorised official authority confirmation documents;
• authorised official(s) and Beneficial Owners recent address confirmation documents for the last 3 (three) months;
• additional documents (if applicable): financial statements, licence confirmation, AML policy, proof of company business address, bank statements and others documents, depending on Customer business activity and jurisdiction.

 

We may apply additional KYC measures in respect of a particular customer and request additional documents for customer’s identification and verification in certain cases set in the Company’s internal AML/CTF/CPF rules and procedures and depending on the customer's assigned ML/TF risk type. Our ML/TF risk assessment is based on the Risk-Based-Approach.

 

Customer electronic identification and verification process is ensured by using third party identity verification services. 

 

We use the electronic identification and identity verification service of reputable, reliable and acceptable partner Sum and Substance LTD (https://sumsub.com//). 

 

We ensure mandatory sanctions (CNB, OFAC, EU, UN, UK sanction lists) and PEP screenings on every customer prior to establishing business relationships with a customer and daily screenings in respect of each existing customer. 

 

These screenings are ensured automatically by integrated software with the Company’s system as well as by services of electronic identification and identity verification service providers.

 

Our staff verifies authenticity of all submitted documents, as well as carefully screens customers against possible negative adverse media.

 

We expect that each customer will provide us with true and accurate information and documents necessary for the KYC process and customer’s identity verification. 

 

We do not establish any business relationships with the customers related to (place of born, citizenship, place of residence, other close ties with certain country) the countries recognized by us as a non-cooperative:

• Afghanistan
• Bahamas
• Barbados
• Botswana
• Cambodia
• Crimea
• Cuba
• Democratic People’s Republic of Korea (DPRK)
• Ghana
• Iran
• Iraq
• Jamaica
• Lebanon
• Libya
• Mauritius
• Myanmar/Burma
• Nicaragua
• Pakistan
• Panama
• Russian Federation
• Syria
• Trinidad and Tobago
• Ukraine’s Luhansk region
• Ukraine’s Donetsk region
• Uganda
• United States of America
• Vanuatu
• Venezuela
• West Bank and Gaza Strip
• Yemen
• Zimbabwe
• Belarus.

 

We may refuse to establish business relationships with the customer and not to provider services, if:

• it is not possible to fully identify the customer,
• any positive sanction match is found in respect of the customer itself, also customer’s director, beneficial owner, representative, partner, 
• customer is engaged in non-cooperative types of industries recognized as such by us (occupation, business type),
• negative adverse media have been detected around the customer itself, also customer’s director, beneficial owner, representative, partner, 
• in other cases, recognized by us posing a significant threat of ML/TF/PF.

 

We ensure ongoing monitoring over the conducted transactions to ensure that they are consistent with those anticipated, that possible grounds to suspect ML/TF/PF will be noticed and scrutinised, and that changes requiring a re-assessment of money laundering risk will be acted upon.

 

This AML Policy is under regular Company’s review and updates.

 

We retain the rights to amend this Policy anytime, notifying the customer in a timely manner. If the customer does not agree to the amendments made, the customer shall stop using our services and shall terminate business relationships established with us in a time and manner set in our Terms of Services.

 

If the customer continues to use our services irrespective of the amendments made by us to this AML Policy, it should be treated as customer’s consent to the amendments made and updated version of this Policy.