Anti Money Laundering / Know Your Customer
PURCOW: AML/KYC POLICY
This document was last updated on Apr ,
The Company protects itself from
involvement in money laundering or suspicious activity by the following:
Establishing detailed AML policies and
Performing know your customer
("KYC") procedures on all users including individuals and corporate
Designating a Compliance Officer with full
responsibility to follow AML policies strictly.
Conducting an AML audit anually .
Policies and Procedures
The Policy will be approved by the
Company¡'s Board. All policies and procedures will be reviewed and updated or
revised as needed, but no less often than annually.
AML Compliance Officer
The Company has a Compliance Officer to be
responsible for the management, coordination and monitoring of compliance with
this policy and all applicable AML laws and regulations. The Compliance Officer
will have a working knowledge of all AML laws and be qualified by knowledge,
experience and training. The Compliance Officer will be responsible for all
record keeping requirements and provide reports on the effectiveness of the AML
program to the Company¡'s Board.
It is the Company¡'s policy to ensure that
it has reasonably identified each customer who uses the Company¡'s virtual
currency trading platform. Users may be identified using a variety of methods.
Account Opening Procedures.
The Company require users to provide proof
of identification; and will not permit any trades to be made by un-verified
Proof of Identification:
Date and place of birth
Contact Phone number
Residence address and mailing address if
different (PO Box address will not be acceptable).
Copy of valid photo identification (e.g.,
Passport number, Government Issued Identification Number, Social security
number, Employee identification number or Individual taxpayer identification
Proof of address (e.g., Utility Bill,
Telephone Bill, Bank Statement, Credit card statement etc.)
Name of businesses representative for the
The proof of address of the customer¡'s
principal place of business and, if different, the customer¡'s mailing address.
If the customer has a local address different from its principal place of
business, the local address.
Copy of valid photo identification for the
directors (e.g., Passport number, Government Issued Identification Number,
Social security number, Employee identification number or Individual taxpayer
Company M & A and profile of the
Users will have option to load the document
electornically from his account. Documents used in opening an account
relationship will be verified prior to establishing the account. Verification
of identity will require multi-factor authentication to ensure a meaningful
user identity confirmation process based on account size or other factors.
The following are examples of verification
methods the Company may use:
Obtaining proof of address, such as a copy
of a utility bill, Telephone bill or bank statement from the account holder.
Having a telephone call to the number given
in account opening form.
Obtaining a financial statement for a
Comparing the identifying information with
information available from a trusted third party source.
Photo ID of the users or the Directors for
the company account.
Obtaining a notarized copy of an
individual¡'s birth certificate or a business¡' certificate of incorporation
sealed with an apostille for valid identification .
When the type of account increases the risk
that the Company will not be able to verify the true identity of the customer
through documents is confirmed the account will be closed.
SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS
The Company will diligently monitor
transactions for suspicious activity. Transactions that are unusual will be
carefully reviewed to determine if it appears that they make no apparent sense
or appear to be for an unlawful purpose. When such suspicious activity is
detected, the Compliance Officer will determine whether a filing with any law
enforcement authority is necessary.
Suspicious activity can include more than
just suspected money laundering attempts. Activity may be suspicious, and the
Company may wish to make a filing with a law enforcement authority, even if no
money is lost as a result of the transaction.
The Compliance Officer will initially make
the decision of whether a transaction is potentially suspicious. Once the
Compliance Officer has finished his review of the transaction details, he or
she will consult with the Company¡'s senior management to make the decision as
to whether the transaction meets the definition of suspicious transaction or
activity and whether any filings with law enforcement authorities should be
Reasonable procedures for maintaining
records of the information used to verify a person¡'s name; address and other
identifying information are required under this Policy. The following are
required steps in the record keeping process:
The Company will maintain a record of
identifying information provided by the customer.
The Company will ecord the methods and
result of any additional measures undertaken to verify the identity of the
All transaction and identification records
will be maintained for a minimum period of five years.
The Compliance Officer is responsible for
directing the annual AML audit of the Company¡'s operations. The Compliance
Officer will provide the audit report and all corrective action plans to the
Company¡'s senior management for review.