KYC/AML Policy

Introduction

The MIMY’s goal is, among others, prevention of its involvement in an activity that is against the law. These activities include the following: money laundering, human trafficking, terrorist financing, and others. They are prohibited by local laws, as well as international ones.

For this reason, MIMY has developed this Know Your Customer and Anti-Money Laundering Policy (hereinafter – the KYC/AML Policy).

Objectives of the KYC/AML Policy:

  • to prevent the use of the Company by criminals to carry out money laundering operations;
  • exercise sufficient control to identify and report suspicious and/or potentially illegal activities in accordance with laws and procedures.

The KYC/AML Policy includes the following procedures:

  1. Client verification.
  2. PEP and sanctions lists checking.
  3. Checking by the Compliance Officer.
  4. Transactions monitoring.
  5. Risk management.

Client Verification

To prevent illegal activity, MIMY can develop a special customer verification process.

The client has to give MIMY valid information and document to carry out identity verification. This can be a passport or national ID card, bank statement, etc.

MIMY will use all legal means to correctly identify the identity of the client. MIMY can also investigate customer actions that look suspicious.

MIMY can carry out regular verification of the client’s identity. This especially concerns those users who changed their identity or took actions that MIMY regarded as suspicious. MIMY can ask clients to re-provide identification information, even if verification has already been performed.

The collection, storage, and sharing of users’ personal information are regulated by MIMY’s Privacy Policy.

All information provided by clients is confidential. MIMY collects customers’ personal information in order to comply with laws and regulations. MIMY does not share this information with third parties.

The user identification procedure helps MIMY avoid liability in case if the user carries out illegal operations.

If a MIMY’s client needs to use a payment card to pay for services, then he has to pass the card verification procedure. The rules for this procedure can be found on the MIMY’s website.

PEP and Sanctions Lists Checking

MIMY uses these two lists to ensure that it has the legal right to provide services to a particular client

A rigorous customer verification program includes the following procedures:

  1. Checking for sanctions is carried out to obtain guarantees that no person on the global lists of law enforcement agencies will be able to perform financial transactions forbidden for him/her.
  2. Politically exposed persons (PEPs) screening is carried out to identify potential fraudsters as part of a due diligence policy towards high-risk politicians or other high-risk clients.

The check is carried out in three cases:

  • on the onboarding stage – when the client submits an application
  • if the client is suspected of fraud
  • automatically every month when checking databases

Checking by The Compliance Officer

The role of the Compliance Officer is to ensure that clients' activities comply with the law. He oversees all phases of MIMY clients' activities associated with certain risks. His responsibilities include:

  1. Collecting data for customer identification.
  2. Regulation of all procedures related to reports.
  3. Suspicious transactions monitoring.
  4. Ensuring proper file and document storage.
  5. Informing law enforcement agencies about offenses.

This list may include other activities.

Transactions Monitoring

MIMY analyzes customer data to identify illegal activities. This also applies to transaction patterns. Collecting information, keeping records, conducting investigations – all these procedures are aimed at preventing illegal activities of MIMY’s customers.

The system can perform the following actions:

  • a daily collation of the list of clients with the generally recognized “blacklists”;
  • adding clients to watch lists;
  • making lists of those who are denied service;
  • filling out the reports;
  • document management, etc.

To ensure that customers comply with the law, MIMY can:

  • monitor all transactions;
  • report suspicious transactions to the authorities;
  • request extended information from the client in case of illegal actions suspicion;
  • temporarily or permanently block the client's account in case of violation of the laws.

This list can be expanded. The decision to classify an action as suspicious or in good faith rests with the Compliance Officer and will be based on daily monitoring of customer transactions.

Risk Management

Acting in accordance with the law, MIMY fights against violation of the law by clients using a risk-based approach. This approach allows using resources more efficiently. The essence of this method is to prioritize and allocate the greatest resources to prevent the most significant risks. Thus, the measures applied are commensurate with the level of threat.