Anti Money Laundering (AML) Policy

17.1
THS is strongly committed to preventing the use of its operations for money laundering or
any activity which facilitates money laundering, or the funding of terrorist or criminal
activities.
17.2
On a global level, in order to prevent and combat money laundering and terrorism
financing, there has been an introduction of the number of laws concerning the customer
identification and verification procedures including but not limited to the EU AMLD5
Directive, which brings the virtual currencies under the scope of the Anti-Money
Laundering Directive.
17.3
In the United States regulation of the AML is carried out by a special government body
under the US Treasury – FinCEN. In particular, FinCEN regulates, so-called, “money
services business” (MSB). In 2013 FinCEN published the clarification on the regulation of
persons administering, exchanging or using virtual currencies bringing the businesses
dealing with virtual currencies under the scope of AML/KYC in terms of spotting suspicious
financial behavior.
17.4
In order to ensure that our operations are compliant with the AML/KYC rules and
procedures, we are implementing the AML/KYC policies detailed below.
17.5
As part of our AML (Anti-Money Laundering) Policy in order to combat money laundering
and illegal financing activities the Company follows the customer risk assessment
principles that include but are not limited to the following: − raise awareness on money
laundering issues; − appoint a designated CCO. The CCO is to report any suspicious
transactions to the appropriate Financial Authority; − assist law agencies and authorities to
trace, seize, and confiscate the proceed of criminal activities; − freeze any funds deemed
suspicious and investigate the source of finance; − introduce a Know-Your-Customer
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THE HASH SPEED(THS)Policy (KYC); − exercise reasonable measures to obtain information about the true identity
of the persons on whose behalf a transaction is made; − record keeping procedures –
maintain, for a specific time period, all necessary records on transactions, both domestic
and international; − pay special attention to all complex, unusually large transactions; −
adopt economic, administrative, self-regulatory and other measures which can be taken to
create an effective shield against money laundering; − train staff accordingly; − employ
proper care in the hiring of new staff.
17.6
As part of the customer risk assessment, the following will act as Money Laundering
Warning Signs based on guidance provided by Financial Action Task Force (FATF) –
international body set up to combat money laundering: − customer tells that the funds are
coming from one source but then at the last minute the source changes; − evasiveness or
reluctance to provide information; − incomplete or inconsistent information; − unusual
money transfer or transactions (e.g. when customer deposits unusual amounts (e.g. 9,990
euros) so as not to come under the threshold when KYC applies); − complex group
structures without obvious explanation that may be designed to disguise the true source
and ownership of money; − when money is coming from the list of ‘high-risk and
non-co-operative jurisdictions’ according to FATF; − negative public information available
about the client or company.
17.7
The above principles and warning signs are aimed at determining the customer’s risk in
terms of propensity to commit money laundering, terrorist financing or identity theft.
17.8
Every Employee is required to act in furtherance of this policy statement to protect the
Company from exploitation by money launderers or terrorists.
17.9
Company adopts the KYC (Know-Your-Customer) Policy and reserves the right to
undertake KYC in order to verify the identity of its customers at any point.
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THE HASH SPEED(THS)17.10
As part of the exercise of this right, the Company may require the following information to
be sent: − copy of passport or national ID; − recent utility bill; − recent bank account
statement ‘Recent’ means no longer than 3 months from date of issue.
17.11
Please note that the list above is not exhaustive and we reserve the right to require
additional information at any time to verify the client’s identification and to fully satisfy the
latest Anti-Money Laundering rules.
17.12
The Personal Information requested as part of the KYC procedure will be collected,
processed, used and stored in accordance with the General Data Protection Regulation
(GDPR), rules and principles of which have been reflected in the THS Privacy Policy and
implemented on the legal, technical and organizational level.
17.13
If any of the above documents are requested, prior to sending them to us we may require
them to be certified as a true copy of the original by a Solicitor or a Lawyer who must use
their company stamp. We require the documents to be sent to us in high quality color
format. We reserve the right to reject any documents, which do not comply with the above
or if we have doubts as to their veracity.
17.14
If any doubt arises we reserve the right to check the information provided, as part of the
KYC Policy, using no documentary methods including but not limited to contacting the
customer directly.
17.15
CCO has a right to freeze any funds already transferred should the suspicion as to the
sources of those funds arise after they have been deposited and investigate the
customer’s transaction in retrospect.