For purposes of this Policy, “us,” “we,” or “our” refer to the website www.lendabit.com and related services.
Our Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) are designated to prevent and mitigate possible risks of us being involved in any kind of illegal activity.
Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity of our customers.
AML/KYC Policy covers the following matters:
The Compliance Officer is the person, duly authorized by us, 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 our anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting customers' 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 the prevention of money laundering, terrorist financing and other illegal activities.
We, in line with the international requirements, have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with 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.
Our identity verification procedure requires the customer during the registering to provide us with such documents according to AML/KYC policies:
a) Identity Document – this is valid, reliable and independent source document with following information: full name; date of birth; customer's photo, identity document serial number. The customer is free to provide one of the following types of documents:
- National ID card (both sides) or national passport;
- International passport;
- Driving license (both sides).
Please note that we accept documents as proof of your identity only if all the information in it is provided with Latin transliteration.
b) Proof of address - this is document which confirming the customer's residence containing full name, address and issued not more than 3 months ago. The customer is free to provide one of the following types of documents:
- Certified tenancy agreement or a bank statement;
- Utility or electricity bill;
- Tax return or council tax;
- Other official document with current resident address, full name and issued not more than 3 months ago.
Please note that we accept documents as proof of address only if all the information in it is provided with Latin transliteration.
c) “Selfie” - photo of yourself holding one of ID documents (mentioned in “a” above) and a sheet of paper with the inscription “LendaBit” and the current date.
We will take steps to confirm the authenticity of documents and information provided by the customer. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain customers who have been determined to be risky or suspicious.
We reserve the right to verify a customer's identity in an on-going basis, especially when his identification information has been changed or his activity seemed to be suspicious (unusual for the particular customer). In addition, we reserve the right to request up-to-date documents from the customer, even though he have passed identity verification in the past.
We reserve a right to reject any person on registering on www.lendabit.com and using related services if we are unable to verify any information due to non-cooperation of the customer, or if customer's actions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.
We may from time to time temporarily reject customers from some countries/territories. The current list of such countries/territories can be reviewed here. This applies to both new customers at the registration stage and existing users of our services. In the latter case, we will notify the client of the refusal to provide services in advance, and provide reasonable time for the termination of the use of our services.
The customers are known not only by verifying their identity (who they are) but, more important, by analyzing their transactional patterns (what they do). Therefore, we rely on data analysis as a risk-assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, recordkeeping, investigation management, and reporting. System functionalities include:
a) A daily check of customers against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing customers on watch and service denial lists, opening cases for investigation if it is essential, sending internal communications and filling out statutory reports, if applicable;
b) Case and document management.
With regard to the AML/KYC Policy, we will analyse all provided customers data and 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 customer to provide any additional information and documents in case of suspicious transactions;
- temporary suspend (block) or terminate customer's account when we have reasonable suspicion that such customer is engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor customers' 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.