Last Update: 1 March 2023
DooshPay Anti-Money Laundering and Know Your Customer Policy (hereinafter the “AML/KYC Policy”) is designed to prevent and mitigate the potential risks of DooshPay being involved in any type of illegal activity.
Both international and local regulations require DooshPay to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take measures in case of any form of suspicious activity of its Users.
The AML/KYC policy covers the following matters:
1 Verification procedures
2 Compliance Officer
3 Transaction Monitoring
4 Risk assessment
1. Verification Procedures
One of the international standards to prevent illegal activities is customer due diligence (“CDD”). According to CDD, DooshPay establishes its own verification procedures within the standards of the anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers who pose a higher risk, such as politically exposed persons ( PEPs).
DooshPay’s identity verification procedure requires the User to provide DooshPay with documents, data or information of reliable and independent origin (for example, national ID, international passport, bank statement, utility bill). For such purposes, DooshPay reserves the right to collect User identification information for the purposes of the AML/KYC Policy.
DooshPay will take steps to confirm the authenticity of documents and information provided by Users. All lawful methods will be used to verify identifying information and DooshPay reserves the right to investigate certain Users who have been determined to be risky or suspicious.
DooshPay reserves the right to verify the User’s identity on an ongoing basis, especially when their identification information has been changed or their activity appears to be suspicious (unusual for the particular User). Furthermore, DooshPay reserves the right to request updated documents from Users, even if they have passed identity verification in the past.
Once the User’s identity has been verified, DooshPay can be removed from possible legal liability in a situation where its Services are used to conduct illegal activities.
DooshPay is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Therefore, DooshPay will face the sanctions lists of the United Nations, the European Union, the United Kingdom Treasury and the United States Office of Foreign Assets Control (OFAC) in all jurisdictions in which we operate.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by DooshPay, whose duty it is to ensure the effective implementation and compliance with the AML/KYC Policy. It is the responsibility of the Compliance Officer to oversee all aspects of DooshPay’s anti-money laundering and anti-terrorist financing, including but not limited to:
- Collect identification information from Users;
- Establish and update internal policies and procedures for the completion, review, filing and retention of all reports and records required under applicable laws and regulations;
- Monitor transactions and investigate any significant deviations from normal activity;
- Periodically update the risk assessment;
- Provide law enforcement with public information as required by applicable laws and regulations.
The Compliance Officer has the right to interact with law enforcement agencies, who are involved in the prevention of money laundering, financing of terrorism and other illegal activities.
3. Transaction Monitoring
Users are known not only for verifying their identity (who they are) but more importantly for analyzing their transactional patterns (what they do). Therefore, DooshPay relies on data analysis as a risk assessment and suspicion detection tool. DooshPay performs a variety of compliance-related tasks, including data capture, filtering, record keeping, investigation management, and reporting. System functionalities include:
1. Daily verification of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and denial of service lists, opening cases for investigation when necessary, sending internal communications and completing legal reports, if applicable;
2. Case and document management.
Regarding AML/KYC Policy, DooshPay will monitor all transactions and reserves the right to:
- Ensuring that transactions of a suspicious nature are reported to the appropriate police through the Compliance Officer;
- Request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate the User’s Account when DooshPay reasonably suspects that the User has engaged in illegal activities.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis to define whether such transactions should be reported and treated as suspicious or should be treated as bona fide.
DooshPay, in line with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By taking a risk-based approach, DooshPay can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with identified risks. This allows resources to be allocated in the most efficient way. The principle is that resources should be directed according to priorities so that the greatest risks receive the most attention.