KYC & AML

 

Policy on Anti-Money Laundering (AML) and Know Your Customer (KYC)

Money laundering involves concealing an illegal source of funds by converting them into seemingly legitimate cash or investments.

General Provisions

Our anti-money laundering policy ("AML Policy," hereinafter) is based on the following essential principles:

Do not establish business relationships with criminals and/or terrorists.
Do not process transactions derived from criminal and/or terrorist activities.
Do not facilitate any transaction related to criminal and/or terrorist activities.

Verification Procedures

The Store has its own procedures to ensure compliance with AML standards and the Know Your Customer (KYC) policy.

Store customers complete a verification process (they must provide a government-issued identification document: passport or national ID card). The Store reserves the right to use customer identification information to adhere to the AML Policy. This information is processed and stored strictly in accordance with the Store's Privacy Policy. The Store verifies the authenticity of the documents and information provided by customers and reserves the right to request additional information from customers identified as potential risks.

If a customer's identification information is updated or if their activity appears suspicious, the Store has the right to request updated documents from the customer, even if the previous documents had been authenticated.

AML-KYC Compliance Officer

The Store has a designated AML Compliance Officer responsible for ensuring compliance with the AML Policy and implementing KYC procedures, including:

Collecting customers' identity information.
Updating and monitoring internal policies and procedures to create, review, submit, and store all necessary reports in compliance with applicable laws and regulations.
Monitoring and reviewing transactions to analyze significant deviations from customers' normal activities.
Establishing a record management system to store and retrieve documents, files, forms, and records.
Regularly analyzing risk assessments.

Transaction Monitoring

Monitoring customer transactions and analyzing the data obtained is a tool used to assess the risk level of these transactions and detect suspicious activity. If money laundering is suspected, the Store will monitor all transactions of the corresponding customer and reserves the right to:

Request additional information and documents from the customer.
Suspend or close the customer’s account.

Record Retention and Reporting of Information

As part of our AML program, we maintain relevant documentation regarding customer identity and electronic fund transfers. The retention period for records is updated according to applicable regulations.

Currently, the retention period is set at ten years. Files must be maintained in a manner that is accessible to all employees requiring customer access.

We will respond to written, justified, and legally binding requests issued by official authorities within the legal framework regarding accounts and transactions. We will search our records to determine whether we hold or have held any information or have conducted transactions with any person, entity, or organization adequately identified and named in the request.

If no information is found, we will provide the relevant response, document the search conducted, and record the name of the individual or entity included in the request for risk-based procedures.

Customer Identification and Source of Funds

We collect specific identifying information from each customer before they conduct any operations:

For Individuals:

Name and any other name used.
National ID, passport number, national identity card, residence permit, or other identification number, or driver’s license number.
Residential information (address and/or utility company customer data, etc.).
Biometric verification.
Any additional customer information required to meet risk-based requirements.

For Companies or Legal Entities:

Company name.
Main place of business information.
Contact details.
Incorporation data (registration number, incorporation date, etc.).
Payment details and/or bank information.
Residence information (address details or utility customer data).
Details of individuals authorized to operate on behalf of the company and their authorization details.
Biometric verification of the entity's manager(s).
Any additional information required to meet risk-based requirements.

We apply relevant risk-based measures to verify the identity of each customer and maintain the necessary records.

Risk Assessment

In accordance with international requirements, the Store applies a risk-based approach to combat criminal actions. Therefore, measures to prevent money laundering and terrorist financing are proportional to identified risks, allowing resources to be allocated effectively. Resources are prioritized based on risk: the higher the risk, the greater the scrutiny.