Clearcrest Inc. UAB (from now on – the Company) is a virtual currency exchange and virtual currency wallet company acting according to the laws of the Republic of Lithuania.
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 Lithuania, 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.
The Company, by implementing measures to prevent money laundering and/or terrorist funding, is guided by the following primary documents issued by the Director of the Financial Crime Investigation Service.
The purpose of those policies is an effective combating of money laundering and terrorist financing (AML / CTF) on our exchange by proper identification of actual users of our accounts and supervision of 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, finance illegal 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 would like to introduce to you some of the general rules and stipulations of our policies that directly concern you and affect our services.
User’s identification
In the first place, 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 verify authenticity with professional external providers’ special software.
We require completing an automated identity check or ID document to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made using special software of professional external providers or, in case of doubts, done manually by our customer support services.
In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues.
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
In the case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who owns the company, who can represent it, where it is based, and what the company’s business is.
Since standards regarding governmental documentation of legal entities are different in each country, the verification of such users 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 such transactions and evaluate if 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 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, as well as the source of money you are using on the exchange.
Unfortunately, If our AML specialists decide 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, Clearcrest Inc. UAB (Coinsdrom.com) may opt to freeze/close the account without further notice. When you decide to use our service again, you must register a new account and submit your complete KYC documentation.
Basic AM / CTF Rules
Our operating rules include, among other things as follows:
- Clearcrest Inc. UAB (Coinsdrom.com) does not accept cash deposits or withdrawals.
- Clearcrest Inc. UAB (Coinsdrom.com) does not accept third parties’ deposits on the user’s account, managing the account on behalf of somebody, joint or shared accounts, etc.
- Clearcrest Inc. UAB (Coinsdrom.com) only provides its buy/sell service to customers’ wallet addresses.
- Clearcrest Inc. UAB (Coinsdrom.com) does not allow any exceptions in the documentation required from users.
- Clearcrest Inc. UAB (Coinsdrom.com) reserves the right to refuse to process the User’s transaction at any time in case of suspicion of AML / CTF risk.
- Following international law, we are not obliged (or even forbidden) to inform our clients if we report their behaviours as suspicious to relevant authorities.
Sanctioned countries
Following 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 our verification of your results in qualifying 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 which 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, Maynmar, 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 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 transition, limits may vary due to periodic audits and verification of the efficiency of our procedures. We will keep you updated if any changes would influence your situation.