KYC / AML policy of Zibb system’s financial platforms

Anti-money laundering policy. Money laundering is the concealment of an illegal source of funds by converting them into funds or investments that look legitimate.

The anti-money laundering policy (hereinafter - "AML / KYC Policy") is intended to prevent and reduce possible risks of Private Limited Company Zibb (ZIBB OÜ / 16067992), hereinafter referred to as "Zibb Company", to be involved in any illegal activity.

In accordance with international and local regulations, Zibb Company implements effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, spreading weapons of mass destruction, corruption and bribery, and to respond to any form of suspicious activity by its Users.

Zibb Company adheres to the following rules:

  • not to enter into business relationships with criminals and / or terrorists;
  • not to process transactions that are the result of criminal and / or terrorist activity;
  • not to facilitate any transactions related to criminal and / or terrorist activities.

Zibb system establishes its own verification procedures in the frames of standards for anti-money laundering - the "Know Your Customer" policy.

The AML / KYC policy includes the Verification procedure, Transactions Monitoring and Risk Assessment.

One of the international standards for the prevention of illegal activity is Customer Due Diligence (“CDD”). To enable this, the Zibb Company implements verification procedures in strict anti-money laundering standards.

Zibb Company’s identification procedure requires the User to provide reliable, independent original documents, data or information (for example, national ID card, international passport, bank statement). For such purposes, Zibb Company reserves the right to collect User’s identification information in order to comply with the AML / KYC Policy.

The Zibb Company will take steps to verify the authenticity of documents and information provided by Users. All legal methods for double-checking identity information will be used and Zibb Company reserves the right to investigate cases of certain Users who have been identified as dangerous or suspicious.

Zibb Company reserves the right to verify the User’s identity on a regular basis, especially when his identification information has been changed or his activity seemed suspicious (unusual for a particular User). Besides, Zibb Company reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past. Also, Zibb Company may request a second document to identify the User: a bank statement or an utility bill not older than 3 months, which contains the full name of the User and his actual place of residence.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Zibb Company Privacy Policy and related regulations.

After confirming the identity of the user, Zibb Company may waive potential legal liability in a situation where the company's services are used to conduct illegal activities.

Users who intend to use payment cards for the purpose of consuming services must undergo card verification in accordance with the instructions available on the Zibb system’s websites.

Zibb Company ensures the effective implementation and observance of AML / KYC policy for anti-money laundering, including money laundering and terrorist financing, including but not limited to the following methods:

Collection of user’s identification information.

Establishment and update of internal policies and procedures for completing, reviewing, submitting and storing all reports and records required by applicable laws and regulations.

Transactions’ monitoring and investigation of any significant deviations from normal actitivity.

Regular update of the risk assessment.

Providing law enforcement agencies with the information they need to comply with applicable laws and regulations.

With regard to the AML / KYC policy, Zibb Company will monitor all transactions and reserves the right to:

  • request from the User any additional information and documents if they carry out suspicious transactions;
  • suspend or terminate the User's account if Zibb Company has a reasonable suspicion that such User is engaged into an illegal activity.

The above list is not full and Zibb Company will monitor users’ transactions on a daily basis to determine if they should be considered as suspicious or conscientious.

Zibb Company, in accordance with international requirements, applies risk assessment practice for preventing money laundering and terrorist financing. By applying risk assessment’s practice for preventing money laundering, Zibb Company ensures proportionality of measures to prevent or mitigate money laundering and terrorist financing with identified risks.

The person responsible for compliance with the AML Policy is an employee of the Zibb Company who is responsible for ensuring the AML Policy is followed. In particular:

  • collection of identification information of Users;
  • creating and updating internal policies and procedures for writing, reviewing, submitting and storing all reports required by existing laws and regulations;
  • transactions’ monitoring and analysis of any significant deviations from the normal activity of Users;
  • establishment of the records management’s system for storing and searching documents, files, forms and logs;
  • regular updating of the risk assessment.

The person responsible for compliance with the AML Policy has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

Monitoring

Monitoring the User's financial sector and analyzing the data obtained is also an instrument for assessing risk and detecting suspicious transactions. If there is money laundering is suspected, Zibb Company monitors all transactions and reserves the right to:

  • report suspicious transactions to the relevant law enforcement agencies;
  • ask the User to provide any additional information and documents;
  • suspend or terminate the User's account.

The above list is not full. The person responsible for compliance with the AML Policy monitors Users' transactions on a daily basis to determine if they should be reported and considered as suspicious.

Risk assessment

In accordance with international requirements, Zibb Company applies the risk-based approach to prevent money laundering and terrorist financing. Thus, measures to prevent money laundering and terrorist financing are commensurate with the identified risks. This allows efficient allocation of resources: they are used in accordance with priorities, the most attention is paid to the greatest risks.