Kikitrade Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designed to maintain proper records of Kikitrade’s customers in accordance with the applicable laws, regulations and requirements and to prevent and mitigate possible risks of Kikitrade being involved in any kind of illegal activity or activity in violation of any applicable laws or regulations.
Both international and local regulations encourage and/or require Kikitrade to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and other illegal activities and to take action in case of any form of suspicious activity from its Users.
- Customer Due Diligence (“CDD”)
One of the international standards for preventing illegal activity is to conduct CDD, whereby Kikitrade establishes its own verification procedures within the widely recognized standards of anti-money laundering and “Know Your Customer” frameworks. Kikitrade may, but is not obliged to, provide limited services to customers prior to conducting CDD as determined by Kikitrade from time to time at its sole and absolute discretion to the extent permitted by the applicable laws.
Kikitrade will take steps to confirm the authenticity of documents and information provided by the Users, including but not limited to authenticating any documents or information provided by Users and verifying the Users’ identities with third party service providers. All legal methods for double-checking identification information will be used and Kikitrade reserves the right to investigate certain Users who have been determined to be risky or suspicious.
For individual Users, Kikitrade shall initially require a copy of a valid photographic identification documents issued by government and a photograph of the User. Kikitrade shall initially conduct a risk assessment based on the materials and any publicly available information relating to the User. Subject to Kikitrade’s assessment and sole discretion, Kikitrade may require the User to submit further supporting documents, including but not limited to proof of address, proof of income, employment record, proof of source of funds, additional identification documents and certified copy of any such documents, to complete the CDD procedure.
Kikitrade reserves the right to verify User’s identity on an on-going basis, especially, but not only, when their identification information has been changed or their activity appear to be suspicious. In addition, Kikitrade reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
Kikitrade reserves the right to at any time refuse service to any User and to suspend any User’s account based on the risks identified or any other suspicious activities without providing a reason to the User. Any assets remaining in a User’s account subsequent to the suspension of the User’s account shall be dealt with in accordance with the Refund Policy contained in Kikitrade’s User Service Agreement as agreed by the Users. Kikitrade shall not be liable for any loss of assets, whether crypto or fiat, resulting from the suspension of a User’s account.
Kikitrade will not establish or maintain a customer or a counterparty relationship with a person designated on any sanction lists published by any credible source or otherwise prohibited by applicable law or regulation.
Subject to the risk assessment conducted by Kikitrade and as determined by Kikitrade at its sole discretion, Kikitrade may refuse service to any User from or transacting with, or intending to transact with, entities from a jurisdiction deemed to be high risk or lack appropriate anti-money laundering and counter-terrorist financing laws by credible sources, including but not limited to the sectioned countries identified by the OFAC.
- Compliance Officer
The Compliance Officer is the person duly authorized by Kikitrade, 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 Kikitrade’s anti-money laundering and counter-terrorist financing effort, including but not limited to:
1) Collecting Users’ identification information.
2) 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.
3) Monitoring transactions and investigating any significant deviations from normal activity.
4) Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
5) Updating risk assessment regularly.
6) Providing law enforcement with information as required under the applicable laws and regulations.
- Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Kikitrade relies on data analysis as a risk-assessment and suspicion detection tool. Kikitrade performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
1) Regular check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and reporting suspicious activities to the authorities as required by any applicable laws, where applicable;
2) Case and document management.
With regard to the AML/KYC Policy, Kikitrade will 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 User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate the User's Account when Kikitrade has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a regular basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
- Risk Assessment
Kikitrade, in line with the international and domestic requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Kikitrade is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are appropriate for the identified risks.