Last revised: 6 May, 2025
1.1. This AML/KYC Policy (hereinafter referred to as the “Policy”) sets forth the rules, principles and procedures that the FinTechSphere s.r.o., its subsidiaries and affiliated parties (hereinafter referred to as the “Company”) follows for detecting and preventing any financial crime, including money laundering and the funding of terrorism, in accordance with all relevant and mandatory applicable laws.
1.2. This Policy is an integral part of the Company’s Terms of Services – i.e. the terms and conditions, which are at all times available on the Company’s Website. The Policy specifies the main and general principles and rules, applicable for the purposes of detecting and preventing any financial crime, including money laundering and the funding of terrorism, in accordance with all relevant and mandatory applicable laws.
1.3. The Company is strongly committed to preventing the use of its Services for money laundering or any other activity which facilitates money laundering, the funding of terrorist and/or any other criminal activities, or any other illicit purposes.
1.4. The Company has its own implemented internal procedures (hereinafter referred to as the “Procedures”), developed and implemented in accordance with the Act No. 297/2008 Coll. on protection against money laundering and terrorist financing and on the amendment to certain acts, as well as other by-laws adopted on the basis of this Act and other applicable, relevant and mandatory legal requirements (hereinafter altogether referred to as the “AML/CFT Laws”). The Procedures are administered by the Company’s Director, the AML Officer (MLRO), and his team, together referred to as the Compliance Department in strict accordance with the AML/CFT Laws.
1.5. The Company’s Compliance Department is tasked with monitoring compliance with the relevant AML/KYC regulations and administrating the Procedures within the Company in strict accordance with applicable laws.
2.1. The Company provides licensed virtual asset services, permitted in accordance with the AML/CFT Laws, as well as specified in the Terms of Services.
2.2. The Company administers and applies its AML/KYC principles, rules, measures and procedures in strict accordance with the AML/CFT Laws for the purposes of detecting and preventing any financial crime, including money laundering and the funding of terrorism and any other illegal activity.
3.1. The Company has its own developed and implemented protection measures, which protect the Company from being involved and the Company’s Users from carrying out any suspicious financial activity, business and transaction(s). For these purposes, the Company:
4.1. As part of the User’s Due Diligence, the Company’s Compliance Department:
4.2. The Company has the right to request additional, new and/or updated data, documents and/or information from any User at any time, even if such User has been identified before in accordance with applicable laws.
4.3. The Company may stop and refuse providing Services to Users and/or report such Users to the authorized government bodies, if they do not provide the Company with requested data, documents and/or information in accordance with applicable laws.
5.1. The Company implements and applies different AML/KYC Verification Levels to detect and prevent any financial crime, including money laundering and the funding of terrorism, in accordance with AML/CFT Laws.
5.2. The Company’s Verification Level, conducted on each User, shall directly influence the amount of activities the User can perform on the Company’s website. For the purposes of the Company’s Verification Levels, the following terms shall have the following meaning:
The Valid ID shall mean document, which contains the following:
● Names and surname;
● Date of birth;
● Place of birth;
● Gender;
● The number of the identity document;
● The date and place of issue;
● The name of the authority which issued it;
● Period of validity;
● Photo.
As Valid ID we accept such documents as national identity card, passport, driving license аnd/or residence permit
The Proof of Residence shall mean a recent (up to 6 months) utility bill (e.g. electricity, water, cable TV, internet line, telephone landline), bank statements, and/or and/or municipal taxes and/or tax invoices.
5.3. In accordance with the applicable AML/CFT Laws, as well as the Company’s internal compliance procedure rules, when making a transaction or a series of linked transactions and/or at any time requested by the Company, a User shall provide a Proof of Funds, which shall mean any document that verified the lawful source of User’s funds, such as copies of accounting documents, tax statements, bank statements and so on.
5.4. For the purposes of the Company’s Verification Levels and/or at any time the Company may also send a User an AML/KYC Questionnaire, which shall mean a series of questions and/or a video-call with the Company’s Compliance Department in order to detect and identify the intent and the source of funds, that are subject to User’s business, transactions and activities, as well as to rule out any illicit purpose.
6.1. When carrying out risk assessment, as well as initial and/or ongoing Procedures, the Company takes into account the risk factors, including the User’s and the geographical risk characteristics.
6.2. When carrying out risk assessment, the Company takes into account the untruthful, false and/or incomplete data, information, documents and facts, including but not limited to discrepancies in ID documents provided, fictitious person, stolen identity, previous financial crime record, terrorist record, wanted person and so on.
6.3. When carrying out risk assessment, the Company also pays attention to the performance of suspicious, high-volume and unusual transactions and/or series of linked transactions by its User(s).
6.4. When carrying out risk assessment, the Company, in accordance with its internal procedure rules, may apply simplified or enhanced AML/KYC measures in accordance with the AML/CFT Laws and based on the results (outcomes) of the risk assessment.
6.5. The Company has its own developed and implemented list of countries, with whom it does not work with. The list of countries is based on the list of countries identified by the EU as high risk, as well as the list of countries identified as being at risk by the Financial Action Task Force (FATF). The lists created by EU and FATF are essential for assessing the risk of Users, transactions and/or business relationships.
7.1. The Company carries out ongoing monitoring of activities to prevent money laundering, terrorism financing, and other illegal activities. As part of the monitoring activities, the Company:
8.1. In an event that the Company reasonably suspects suspicious transaction(s), it shall conduct additional questioning regarding the User’s activity by the means of the AML/KYC Questionnaire, and request any additional data, documents and/or information, that may be required for these purposes and in accordance with applicable AML/CFT Laws, as well as regulatory requirements and guidelines.
8.2. In case the User has not provided any data, document, information and explanation about the suspicious transaction(s), a complete set of requested documents, and/or has presented suspicious or unusual data, documents and other information that the Company cannot verify, the Company will reasonably suspect that the User’s business, activities and transaction(s) may be connected to money laundering, terrorism financing or other illegal activity, business and transaction(s). In such cases the Company files a report on the website of authorized government body, reporting the suspicious activity, business and transaction(s) and reserves the right to suspend the User’s account, suspected of such activities, business and transaction(s) at its sole discretion.
9.1. If you have any questions about this AML/KYC Policy, procedures and/or any other AML/KYC-related matters or any complaints about Company’s Services, you may contact us at compliance@valts.io.