AML policy

This procedure establishes the order of realizing the requirements of law regulations, which regulate money laundering and terrorist financing prevention.
 
In the field of providing virtual currency payment processing and exchange services, there is a commitment to conduct due diligence on our clients and ensure that all applicable laws and regulations are necessary to forestall and prevent money laundering. These include the process of verification - confirming the identity and personal information of our sellers and buyers. Some of the following documents, but not only, might be required during the verification process:
  • Government issued International Passport
  • Government issued Identity Card
  • Government issued Driving License 
  • Selfie with Identity Document
  • Utility bill or Bank Statement, not older than 6 months (paper versions or electronic versions are allowed, no modifications are allowed to the documents)
  • Photo of Credit Card (in specific cases, only when making a payment with your Debit/Credit Cards)
  • Selfie with Credit Card (in specific cases, only when making a payment with your Debit/Credit Cards)
  • Photo with a printed or handwritten declaration (in specific cases, for high amounts)
Please note: All required documents should be provided in good quality, all texts should be readable, there should not be any modifications or edits of the document photos, otherwise we would have to reject them and request new copies without modification or in better quality. 
 
In order to ensure comprehensive prevention, while examining and defining the identity of the customer and beneficiary, the company must rely on documents, data, or information obtained from a reliable and independent source: the information provided by the bank of the customer, official documents, which contain personal photography and/or the corresponding registration number, are unable to be easily copied or forged (passport, identity card, driving license), which indicate the name of the customer, surname, personal identification number or another unique sequence of numbers for the identification of a person, a personal picture and (or) the signature, etc.; publicly available information by databases; by the recommendations of the other credit institutions, etc.;
 
Verifying the identity of the customers, attention is paid whether the customer is not entered in the list of consolidated individuals, their groups, and companies with institutions, which carry the financial penalties of the European Union.
It is prohibited for the employees of the company to run the monetary operations if the client does not provide the documents verifying his identity, provides incomplete or false data, which is known for the employees of the company, avoids providing information, necessary for identification or the provided data is insufficient. 
 
In case of disapproval from the customer to verify the identity by the indicated means or causing suspicions due to performed actions, the company can report this issue to the corresponding institutions. 
 
All the transactions made by clients are monitored. All suspicious operations of the clients are traced and also those operations, which were made under irregular circumstances. If an illegal activity or money laundering is suspected, there is a full right to cancel such a transaction at any step.

According to international law, there is no obligation to give the client any notifications about suspicion of the client’s criminal actions. Such actions are based on AML FATF references.
 
Transaction records are maintained and customer due diligence information and makes this information available to competent authorities upon request.
 
Furthermore, the right to conduct enhanced due diligence on all clients given worldwide approved risk-based policies is reserved. Please note that the right to refuse a transaction or deny operation on a client or account at any time should suspicion arise that it may be connected to money laundering, criminal activity, or any other predicate offense to money laundering is reserved. Wunderbit will not enter into any business arrangement with anyone or group suspected of or directly involved in money laundering, or where funds have been sources or ends of illegal activity.
 
In the event of receiving, during its request for documentation, deceptive documentation, contact details, or other false information,  the offending account will be terminated. Such misdemeanors to the relevant authorities, and as such, the subject may be the subject to a criminal investigation will be reported.
Providing false, doctored, or deceptive documents is considered as fraud and will be treated as such. Tax Evasion and Fraud is a predicate offense to money laundering, and therefore, all assets derived from fraudulent transactions or suspicious activity may be seized and forfeited.
To prevent suspicious operations and verify the client’s identity, there is a right to update its electronic system on a regular basis according to new regulations (if those appear). Different pieces of training for the staff for improving the methods of struggle against money laundering are arranged.

Counter-Terrorism Financing Statement (CTF)

As part of the information that is collected during our verification and AML procedures, the right to conduct verification through worldwide databases is reserved. At the forefront, they will include global sanctions reports and government watch lists, and rigorous screening processes. At any time, due to a requirement to satisfy any of the above verification methods, a client may be asked a specific document or piece of information to confirm their identity or provide additional information regarding any transaction, operations, or even business dealings with certain individuals, institutions and dealings in geographical locations.
Should a situation arise where the nature of geographical specific regulations or account activity fall within the scope of non-compliance in any applicable law or regulation, the client of the event and occurrence will be informed. For such instances, pre-verification and enhanced due diligence will be required prior to regaining active account status. In cases, where compliance is not achieved pursuing remediation measures, we will see fit to terminate the account and may report the event and surroundings to the applicable law enforcement and regulatory authorities.

Obligations to the user

a) By using Wunderbit services, I confirm that me or close family members* or close associates** are not politically exposed natural persons. Otherwise, I will inform Wunderbit about this situation by writing a notice to e-mail [email protected] 

*Close family members mean the spouse, the person with whom partnership has been registered (hereinafter referred to as cohabitant), the parents, brothers, sisters, grandparents, grandchildren, children and children's spouses, children's cohabitants. 

**Close associate means a natural person who, together with the person who is or has been participating in the same legal person or maintains other business relations. 

b) By using Wunderbit services I hereby confirm that I am the actual owner (beneficiary) of funds. 

c) By using Wunderbit services I hereby confirm that I undertake all operations on my behalf and I am not authorized by any other person to undertake operations on his/her/its behalf. Otherwise, I will inform Wunderbit about this situation by writing a notice to e-mail [email protected] 

d) By using Wunderbit services I hereby confirm that I will not use Wunderbit services for any unlawful purpose or in furtherance of any unlawful purpose. 
Among the activities and services constituting of illegal purposes are (but are not limited to): human trafficking (including child pornography); violence; financial crime; smuggling (including narcotics, weapons, drugs, tobacco, etc.); cybercrime; and white-collar crime and corruption. 
In addition, as part of the activities and services which may not, in some jurisdictions, constitute illegal purposes but which are still unauthorized by Wunderbit, are: gambling (as all these normally require local registration and licensing); activities and services related to violation of intellectual property rights; and Initial Coin Offering (ICOs), if not previously reviewed.

e) Without derogating from the above, I hereby confirm that I am not engaged in any adult, obscene, pornographic, defamatory, libelous, infringing, abusive, or illegal activity, or any activity that promotes hate or discrimination, facilitates the sale of firearms or illegal drugs, or that participates or encourages participation in, illegal activities.