AML/KYC POLICY

1. Introduction

The anti-money laundering and “Know your client” policy (hereinafter – “AML / KYC Policy”) is designed to prevent and reduce the possible risks of 24bestex being involved in any illegal activity.

2. Purpose of Internal Regulation

The 24bestex service adheres to practices and measures in the field of counteracting the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that 24bestex takes seriously any attempt to use its service for illegal purposes.

3. Prevention

The 24bestex service warns users against attempts to use the 24bestex service war legalize money obtained by criminal means, financing terrorism, fraud of any kind, as well as from using the service to purchase prohibited goods and services.

The 24bestex service, its administration, employees and domain owners are not responsible for the unlawful use of the service by third parties, the actions of attackers and possible damage associated with the use of the 24bestex service.

4. Requirements

24bestex service sets certain requirements for all Applications created by the User to prevent illegal operations:

1. The sender and receiver of the Payment on the Application must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited;
2. All contact data entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be relevant and reliable;
3. Сreating Applications by the User using anonymous proxy servers, VPN, Tor, or any other anonymous Internet connections is strictly forbidden.

5. Verification procedures

Customer due diligence (“CDD”) has become one of the international standards for preventing illegal activity. Thus, 24bestex implements its verification procedures within the strict standards of anti-money laundering and counter-terrorist financing procedures.

1. 24bestex Service may require the User to provide 24bestex Service with reliable, independent source documents, data or information (for example, a national ID card, international passport, bank statement). For such purposes, 24bestex service reserves the right to collect the User’s identification information for the purposes of AML/CFT and KYC compliance;
2. 24bestex service will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used and 24bestex service reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious;
3. 24bestex service reserves the right to verify the identity of the User on an ongoing basis, especially when its identification information has been changed or its activities appear suspicious (unusual for a particular User). In addition, 24bestex service reserves the right to request from the Users current documents, even if they have been authenticated in the past;
4. Information about the user’s identification will be collected, stored, shared and protected strictly in accordance with the 24bestex service Privacy Policy and relevant rules;
5. After confirming the identity of the user, 24bestex service may refuse to provide services to the User if 24bestex’s services are used to conducting illegal activities;
6. Users who intend to use payment cards for the purpose of consuming services must undergo a card check in accordance with the instructions available on the 24bestex service’s website;
7. 24bestex service has a regulatory requirement to verify the source of fiat funds or cryptocurrency to know that the sources of the funds that customers use to trade with are legitimate;

6. Compliance Officer

The Compliance Officer is the person, duly authorized by 24bestex service, whose duty is to ensure the effective implementation and enforcement of the AML/CFT and KYC Policy.

1. It is the Compliance Officer’s responsibility to supervise all aspects of 24bestex service anti-money laundering and counter-terrorist financing procedures, including, but not limited to the following methods:
   • user identification information collection,
   • creating and updating internal policies and procedures to complete, review, submit and store all reports and records required in accordance with applicable laws and regulations,
   • transaction monitoring and investigation of any significant deviations from normal activities,
   • introduction of a records management systеm for the appropriate storage and retrieval of documents, files, forms and logs;
   • regular updating of the risk assessment,
   • providing law enforcement authorities with the information necessary in accordance with applicable laws and regulations.
2. 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.

7. systеm features

24bestex service performs many compliance tasks, including data collection, filtering, record-keeping, investigation management and reporting. systеm features inсlude:

• daily check of Users on the presence in the 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 filling out statutory reports, if applicable;
• case and document management.

8. Behavioral analysis

The 24bestex service verifies Users not only by verifying their identity but, more importantly, by analyzing their behavior in transactions. Therefore 24bestex service relies on data analysis as a tool for risk assessment and detection of suspicions.

9. Risk Assessment

24bestex service, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, 24bestex service is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks.

10. Performance of Client Checks

If there are reasonable suspicions in the administration of the 24bestex service that the user is trying to use the services of the Service for money laundering or for the purpose of any other illegal operations, the administration has the right:

• suspend the user’s exchange operation;
• request from the User identity documents;
• request from the User any additional information and documents in case of suspicious transactions;
• ensure those suspicious transactions are reported to the appropriate law enforcement authorities through an Compliance Officer.

In order to counter the legalization of proceeds from crime and the financing of terrorism, the service carries out AML-verification of transactions.
In the event that the AML verification of the transaction sent by the client shows a significant risk of more than 70%, the financial operation is suspended.
The user needs to go through the AML KYC identity verification procedure and send the necessary documents within 48 hours. If the verification is confirmed, the funds will be returned to the client to the wallet from which the payment was made no earlier than in 7 working days. The service charges a commission on financial and labor costs of 0.5%.

11. Confidentiality

24bestex service guarantees customer confidentiality in accordance with the privacy policy

1. Both the 24bestex service and its employee are obliged to remain confidential with respect to any facts learned in relevance with any Dubious Transaction. This obligation applies towards both third parties as well as persons affected by the information disclosed.
2. The confidentiality obligation vested in employees of the 24bestex service shall survive any termination of their employment or any other contractual relationship with the 24bestex service or any transfer of such employees to another workplace. Disclosure of such information to public authorities and other entities in cases defined by the law shall not constitute a breach of the confidentiality obligation.
3. The confidentiality obligation provided the use of information disclosed is limited to prevention of legitimization of proceeds of crime and financing of terrorism, cannot be applied to disclosure of information between financial institutions forming a consolidated group within the 24bestex service.

12. Conclusion

In connection with the foregoing, 24bestex service does not bear any legal responsibility for using it to legalize money obtained through criminal means, financing terrorism or purchasing prohibited goods and services, but undertakes to take all possible and affordable actions to prevent attempts to use the 24bestex service for the legalization of funds obtained by criminal means, the financing of terrorism or the purchase of prohibited goods and services.

When making an exchange, the User according to clause 13.7 current exchange rules agrees with all terms of these policies and agrees to comply with them.