AML & KYC policy

Centralex Sp. z o.o. (from now on – the Company) is a virtual currency exchange and virtual currency wallet company, acting according to the laws of the Republic of Poland.

The Company is committed to conducting business operations transparently and openly, consistent with its regulatory obligations. This policy implements the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Poland, dated 19 June 1997 No VIII-275 No XIII-2584 (from now on – the Law) by establishing rules that must be adhered to by the Company to properly manage risks of money laundering and/or terrorist financing. By implementing measures to prevent money laundering and / or terrorist financing, the Company is guided by the following main documents issued by the Director of the Financial Crime Investigation Service.

The purpose of those policies is to effectively combat money laundering and terrorist financing (AML / CTF) on our exchange by correctly identifying actual users of our accounts and supervising their transactions. We shall identify and cease transactions made not only to purchase/sell a cryptocurrency but made mainly to hide the criminal origin of money, illegal finance activity, or other unlawful behaviours.

Specific provisions of our policies are confidential and for internal use only to prevent their avoidance by dishonest or fraudulent users. We want to introduce some of the general rules and stipulations of our policies that directly concern you and affect our services.

USER’S IDENTIFICATION

First, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to do transactions on our exchange. This is why we collect ID scans, which are verified by special software from professional external providers.

We require completing an automated identity check or ID document to prevent someone else from using your documents. Our customer support services verify your likeness to the photo on your ID using special software from professional external providers or, in case of doubts, manually.

If you have any doubts, our customer support team will contact you to explain any concerns and solve any issues that arise.

If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are authentic, we won’t be able to let you execute any transactions.

USER’S IDENTIFICATION – COMPANIES

The procedure is more stringent for all legal entities (companies) and depends on the company’s structure, country, etc. Primarily, we need to establish who owns the company, who can represent it, where the company is based, and what its business is.

Since standards regarding governmental documentation of legal entities are different in each country, verifying such users every time is done “manually” and is considerably more time-consuming.

TRANSACTIONS MONITORING AND SUPERVISION

Using our proprietary software, we also analyse all transactions on our exchange, looking for suspicious and unusual behaviour. Our AML specialists analyse selected transactions and evaluate whether they do not provide significant AML / CTF risks or if they need to be ceased and clarified with the User.

ADDITIONAL VERIFICATION

Our AML / CTF verification duties also increase when your trade volume rises. The same happens when your transactions are “flagged” as suspicious or unusual or when our verification of your results qualifies you as a person imposing significant AML / CTF risk.

In such cases, we can require additional documentation proving your real, exact place of residence, education, occupation, and the source of money you are using on the exchange.

Unfortunately, If our AML specialists decide that the information received from you doesn’t clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to the relevant authorities.

In terms of the provision of the policy of the Anti-Money Laundering Act and our Terms of Service of the licensed financial institution, the update of the KYC documents for all accounts is carried out at periodic intervals. The customer account requires a KYC update once in 6 (six) months, and you will be requested to submit the KYC documents to keep your account active. If KYC still needs to be updated by submitting the documents, Centralex Sp. z o.o. (Bitcomma.com) may opt to freeze/close the account without further notice. When you decide to use our service again, you will have to register a new account and submit your complete KYC documentation.

BASIC AM / CTF RULES

Our operating rules include, among other things as follows:

Centralex Sp. z o.o. (Bitcomma.com) does not accept cash deposits or cash withdrawals.
Centralex Sp. z o.o. (Bitcomma.com) does not accept deposits from third parties on the user’s account, managing the account on behalf of somebody, joint or shared accounts, etc.
Centralex Sp. z o.o. (Bitcomma.com) provides its buy/sell service only to customers’ personal wallet addresses.
Centralex Sp. z o.o. (Bitcomma.com) does not allow any exceptions in the field of documentation required from users.
Centralex Sp. z o.o. (Bitcomma.com) reserves the right to refuse to process the User’s transaction at any time if there is suspicion of AML / CTF risk.
In accordance with international law, we are not obliged (or even forbidden) to inform our clients if we report their suspicious behaviour to relevant authorities.

SANCTIONED COUNTRIES

By our policies, we do not open accounts when your trade volume rises, and our AML / CTF verification duties also increase. The same happens when your transactions are “flagged” as suspicious or unusual or when our verification of your results qualifies you as a person imposing significant AML / CTF risk. And do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations or countries based on various criteria selected by our AML team (for example, Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission), impose high AML / CTF high risk.

CURRENTLY, THESE COUNTRIES ARE:

Afghanistan, Albania, Algeria, Bahamas, Barbados, Belarus, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands, Central African Republic, China, Congo, Cuba, Democratic Republic of Congo, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Israel, Jamaica, Japan, Jordan, Kyrgyzstan, Lebanon, Libya, Mali, Malta, Myanmar, Morocco, Mozambique, Niger, Nigeria, Nicaragua, Pakistan, Palestine Territory, Panama, Philippines, Puerto Rico, Russia, Senegal, Serbia, Somalia, South Sudan, Sudan, Saudi Arabia, Syria, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, Uzbekistan, United States, Venezuela, Virgin Islands U.S., Yemen, Zimbabwe.

TIERS OF KYC VERIFICATION

When your trade volume rises, AML / CTF risk increases, so we must introduce proper safety and verification procedures. As a result, we introduced two-tier verification systems based on the general rule that the more money (or cryptocurrencies) you deposit or want to withdraw, the more information about you and your funds we need to exclude AML / CTF risks (as we are required by law).

You should remember that this model is a result of the work and experience of our AML team and can be changed as the legal requirements of countries change, as well as a result of gaining new knowledge and experience. In particular, during the transition, limits may change due to periodic audits and verification of the efficiency of our procedures. We will keep you updated if any changes would influence your situation.