Centropay - Services for Payment Businesses

AML Policy

PREAMBLE

Financial institutions and closely related entities, such as cryptocurrency exchanges, often experience attempts of money laundering and terrorist financing. In view of the fact that money laundering will undermine the development of digital asset exchange, facilitate and breed corruption, pollute social morality, damage the legitimate rights and interests of Users, destroy the foundation for the sound operation of digital assets exchanging companies, increase the legal and operational risks of digital assets exchanging companies, Centropay Sp. Z O.O. formulates these Rules in accordance with the other relevant documentation, so as to prevent money laundering and terrorist financing and fully comply with relevant regulations against money laundering and terrorist financing.

For further usage of represented terminology, please be aware that money laundering is defined as the process where the identity is disguised that it gives the appearance of legitimate income, while Terrorist financing is defined as the process of providing support to an individual or a group of terrorists. Without direct terrorist financing, such activities as fundraising, use, possession, and funding arrangements also fall under the definition of terrorist financing.

According to above mentioned information, “Centropay Sp. Z O.O.” pays thorough attention to any kind of activity that may be considered as money laundering or terrorist financing. ‘Centropay Sp. Z O.O." AML policy is designed to prevent money laundering by complying with FIU AML legislation obligations, including the need to have adequate systems and controls in place to mitigate the risk of being used to facilitate financial crime. To minimize and mitigate the risk of money laundering and/or terrorist financing.

  • Establishment of the identity of Centropay Sp. Z O.O. customer;
  • Assessment of risk;
  • Monitoring of the customer’s activities; and internal control
  • Reporting of suspicious activities to respective authorities.

General requirements of the company

Before the Company can execute any transaction for any new client, a number of procedures need to be in place and carried out:

  • AML/KYC procedures including customer identification, record-keeping, discovering and monitoring of unusual or suspicious transactions, internal/external reporting and control;

Establishment of the identity

For individual users

For “Centropay Sp. Z O.O.” to be able to establish the identity of its customer, we must obtain sufficient data/documents/information from a customer and verify such data/documents/information against independent sources. This kind of information could include personal information: your name, address (and permanent address if the two are different), date of birth, and nationality, valid photo, contact information as a telephone/mobile phone number, valid email address, and other information available. Identity authentication shall be based on documents issued by the official or other similar authorities, such as passports, identity cards, or other identity documents as are required and issued by relevant jurisdictions.

For institutional users

For “Centropay Sp. Z O.O.” to be able to establish the identity of its institutional users, we must obtain sufficient data/documents/information from a customer and verify such data/documents/information that could include: name of the institution; registered office address of the institution; contact information of the institution; articles of association of the institution; description of the equity structure and ownership of the institution; legal representative of the institution; place of residence of the legal representative of the institution; contact information of the legal representative of the institution; the institution’s business license; the institution’s consent to open an account with this Platform; letter of authorization by the institution; a copy of the valid Identity Card or a valid passport of the legal representative of the institution; and other information or documents to be provided upon request by the company.

Submission and Review of user Documents

The company will verify and record the relevant information submitted by the individual/institutional users in accordance with the user identification system under the platform’s relevant regulations against money laundering. If the Platform has any doubt about the information submitted by any User, it has the right to ask the User to provide other documents or consult with relevant competent authorities or departments for verification.

Re-establishment of the identity

Centropay Sp. Z O.O. retains the right to re-establish the identity of the customer in cases where Centropay Sp. Z O.O. sees it fit, and in relation to that request additional data/documents/information or renew previously submitted.

The customer’s identification information will be collected, stored, shared, and protected strictly in accordance with Centropay Sp. Z O.O. Privacy Notice and related regulations.

Company Address:
Centropay Sp. Z O.O.
ul. Grzybowska 87,
Warszawa, Poland

Centropay

Centropay Sp. Z O.O., ul. Grzybowska 87, Warszawa, Polska.