This document was last updated on September 1, 2019
Yomer OÜ (hereinafter referred as “The Company”) Anti-Money Laundering and Know Your Customer Policy (AML-KYС Policy) is designed to prevent money laundering by meeting the Estonian AML/CFT legislation obligations including the need to have adequate systems and controls to mitigate the risk of being used to promote financial crime. The Company reserves the right to refuse registration to persons from jurisdictions that do not meet international AML-CFT standards.
Money laundering is a process, where money derived from illegal sources are introduced into the legal circulation. The main task of a person involved in the money laundering is a transformation of money into money or other financial instruments to hide as many traces of such illegal operation as possible. The Company takes all possible measures to prevent precedents where any of its customers can use the provided services for similar purposes.
The Company adheres to the following policy in the field of counteracting the legalization of proceeds from crime and the financing of terrorism by taking into account the concerns expressed by regulators of many countries, concerning the potential possibility of using crypto assets for illegal purposes, in particular, for the legalization of proceeds from crime and recognizing complete anonymity in the transactions of money transfers and purchase-sale of crypto assets, which contradicts the interests of its customers.
To monitor compliance with the legislation, the Company develops AML/KYC procedures, which are mandatory for compliance by all employees of the Company and policy-defining interactions with persons who enter into an agreement with the Company and become clients of the Company (hereinafter referred to as the “Customers”).
In order to protect the funds of our Customers and to ensure compliance with the world trade standards the Company works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities:
The Company compliance shall ensure that the Company’s activities comply with international standards of Anti-Money Laundering Policy and all documents provided by the Customers are relevant and comply with the requirements of the law.
All questions concerning this Policy please send to the address:
Yomer OÜ, Kiriku 6, Narva, Ida-Virumaa, 20308
The goal of this Policy is to comply with relevant legislation and normative legal acts, and demonstrate that the Company takes seriously any attempt to use its services for illegal and unlawful purposes.
Legislation obliges the Company to take the necessary measures to prevent and identify cases of money laundering. The Company, in its turn, makes sure that the internal guidelines, procedures and controls used by competent specialists properly and always comply with the latest requirements and innovations.
The Company applies the verification procedure for all new Customers and can not start business relations until the identification of a new Customer is successfully confirmed.
Regulations require the Company to have:
To comply with the policy of counteracting the legalization and laundering of illegal funds, the Company performs the following:
In case the Company specialists in the course of monitoring will find out that any of the Customers use the Company’s services for money laundering, the company reserves the right to block the Customer’s account and all stored funds until the end of the internal investigation.
The Company also reserves the right to provide this information to the police, the authorized regulator or any other control body without the consent of the Customer.
According to the existing standards and requirements the Company has implemented the following measures:
Based on Money Laundering and Terrorist Financing Prevention Act we have to identify and verify any person who enters in a business relationship with us or who has an occasional transaction, including any person acting on their behalf and any beneficial owners.
Identification required for all customers who have registered of an account (personal or corporate) at https://yomer.com, regardless of the added (deposit) amount or send (withdrawal) amount available on the balance to a bank account or any other payment system. The identification procedure is a prerequisite for any financial and exchange operations, until completion of the identification procedure, Customer account is unverified and has restrictions for making financial transactions and transfers.
The Customer understands that the name, address, telephone number and any other personal information, including documents (such as passport, national identity card, driving license, bank account statement, telephone bills, electricity bills or other utility bills) must be true and valid on the upload date.
For legal entities:
The verification process is performed once and can be re-initiated only when the Customer’s registration data or documents are changed. After assigning to the Customer “Verified” status, the re-submission of the verification documents is not required.
The Company reserves the right to repeat the identity verification for the purposes of compliance with the AML/KYC regulations.
To prevent compromising of Customer’s personal data, documents uploading and data entry is done through a secure interface in the Customer’s local area (secure log-in) using encrypted protocol.
Under this Policy, any customer who decides to use the services of the Company also agrees to provide identification and verification documents that confirm identity, address and financial status, among them:
For legal entities:
The Company does not accept the following types of documents as proof of address: phone bill (statement), driving license, couriers receipts, documents issued by the pension fund or insurance companies, the invoices from the shops and other companies in the area of trade and service, credit/debit card statements issued by a store or another bank agent.
Corporate customers (legal entities) provide documents certified in established order by themselves or by a notary.
Copies of supporting documents must be submitted in color, at high resolution (at least 1920×1080), JPEG, JPG, GIF, PDF, max. capacity of each document should not exceed 10 Mb. The Company reserves the right to decline the documents that do not correspond to the above requirements.
According to the existing standards and requirements in anti-money laundering the Company reserves the right at any time to request the customer to present additional documents or any additional information needed for identification.
The Company can freeze (block) the account of any Customer in case of suspicion of fraudulent activity, which may be related to the money laundering, or in case of the customer refuses to provide the requested identification documents.
If the Customer refuses to provide the requested documents and information as a response to a request from the Company without proper justification, the Company will not start a contractual relationship with this Customer, and may also notify this fact to the authorized regulator. This can lead to the suspicion that the Customer is engaged in money laundering and the financing of terrorism.
If the account has been blocked and further investigation and interaction with the Customer cause problems that can not be resolved, the Company can close the account and return all funds from the balance to the source from which they were received.
Company collect a wide range of personal information through the Services. This information varies depending on the verification proceeding during the application, but may include such information as: name, physical address, email address, telephone number, social security number, driver’s license number, state or national ID card number, passport number, other ID card number, date of birth.
Company may also collect a visually scanned or photographed image of your face and/or your identification card, driver’s license, passport, utility bill, bank account statement, insurance card, or credit/debit card. This image may include your photograph and other information from the imaged document, such as your eye color, weight, height.
Extended due diligence is carried out with respect to politically exposed persons, and/or in the presence of the signs specified in the internal Company’s policy and procedures.
If the Company has assessed that the business relationship with the Customer poses a high risk it will apply the following additional measures:
The Company will conduct ongoing Customer due diligence and account monitoring for all business relationships with Customers. It particularly involves regularly reviewing and refreshing Company’s view of what its Customers are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Customer. It can also include anything that appears to be a material change in the nature or purpose of the Customer’s business relationship with the Company.
The Customer is known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, the Company relies on data analysis as a risk-assessment and suspicion detection tool. The Company performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
With regard to the AML-KYC Policy, the Company will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor Customer’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as conscientious.
Customer understand and agrees that the information provided by him for verification may be collected with the help of (and may be stored and processed) by our KYC specialized service providers, in particular BASIS ID, operating as DATA DEPOT ASIA PTE. LTD., a Singapore limited company (company number 201713091C) having its registered address at Block79 @ Launchpad 79 Ayer Rajah Crescent, 05#08 Singapore, 139955 (the “Service Provider”).
The Company, 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, the Company is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
While we welcome clients from all over the globe, governmental restrictions along with our company policies prohibit CoinDeal.com from opening accounts originated from the following restricted and/or OFAC sanctioned countries: Angola, Burundi, Cambodia, Cameroon, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Guinea Bissau, Haiti, Iran, Iraq, Libya, Madagascar, Mozambique, Myanmar, North Korea, Pakistan, Rwanda, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Tajikistan, Tunisia, Turkmenistan, Uzbekistan, Venezuela, Yemen, Zimbabwe.