ECOWATT DIGITAL Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of ECOWATT DIGITAL being involved in any kind of illegal activity.
Both international and local regulations require ECOWATT DIGITAL 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 from its Users.
AML/KYC Policy covers the following matters:
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). ECOWATT DIGITAL will use automated KYC identity verification provided by Onfido.
ECOWATT DIGITAL’s identity verification procedure requires the User to provide ECOWATT DIGITAL with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes ECOWATT DIGITAL reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
All legal methods for double-checking identification information will be used and ECOWATT DIGITAL reserves the right to investigate certain Users who have been determined to be risky or suspicious.
ECOWATT DIGITAL reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, ECOWATT DIGITAL reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly in accordance with the ECOWATT DIGITAL’s Privacy Policy and related regulations.
Once the User’s identity has been verified, ECOWATT DIGITAL is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
The Users who are intended to use payment cards in connection with the ECOWATT DIGITAL’s Services have to pass card verification in accordance with the card service providers verification process.
ECOWATT DIGITAL screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
For the politically exposed persons (PEPs) and sanctions screening process ECOWATT DIGITAL uses automated verification platform provided by Onfido.
The Compliance Officer is the person, duly authorized by ECOWATT DIGITAL, 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 ECOWATT DIGITAL’s anti-money laundering and counter-terrorist financing, including but not limited to:
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity
The Users are known not only by verifying their identity (who they are) but, more importantly, by analysing their transactional patterns (what they do). Therefore, ECOWATT DIGITAL relies on data analysis as a risk-assessment and suspicion detection tool. ECOWATT DIGITAL performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
With regard to the AML/KYC Policy, ECOWATT DIGITAL will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor Users’ 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.
ECOWATT DIGITAL, in line with the international requirements, has adopted a riskbased approach to combating money laundering and terrorist financing. By adopting a risk-based approach, ECOWATT DIGITAL is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to 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.