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CALMSWAP S.R.O. AML
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:
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:
For KYC purposes each customer – legal entity, should provide us at least:
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:
We may refuse to establish business relationships with the customer and not to provider services, if:
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.
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