Anti-Money Laundering and Know Your Customer Policy
Torque Squad Anti-Money Laundering and Know Your Customer Policy (hereinafter – “AML and KYC Policy”) is designated to prevent and mitigate possible risks of us being involved in any kind of illegal activity.
Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
This AML and KYC Policy applies to both natural and legal persons.
1. Verification procedures.
One of the international standards for the prevention of illegal activities is Know Your Customer (“KYC”). In order to be able to access goods and services available on the Torque Squad platform (the “Platform”) or to be able to acquire non-fungible tokens (“NFTs”), any User shall register on the Platform and pass the “KYC” identification process. According to the KYC process, we establish our own verification procedures within the framework of anti-money laundering standards and Know Your Customer.
1.2. Identity verification
Our identity verification procedure requires the User to provide reliable independent sources of documents, data or information (e.g. ID card, international passport, bank statement, utility bills) to our satisfaction during the registration of an Account of a User. For AML and KYC Policy purposes, we hereby reserve the right to collect User information.
1.3. Anti-money laundering procedure
Our anti-money laundering procedure requires the User to provide information about the source of the funds the User uses to purchase NFTs tokens every time the User is requested to provide certain information. We are not responsible for any errors or omissions in the information provided by the User.
1.4. Authenticity verification
We shall take steps to verify the authenticity of documents and information provided by Users, use all legal methods to double-check identification information and hereby reserves the right to investigate the actions of certain Users that have been found risky or suspicious.
1.5. Right to report
We may therefore report our suspicions regarding any activity of the users to local regulators, enforcement bodies and other compliance bodies. Those kinds of actions have a goal of ensuring that the capital being used on our platform has a legitimate origin and create a safeguard in case of individuals or groups wanting to allocate their money from illegal activities on our platform.
1.6. Continuous basis of information verification
1.7. Transaction proceed refusal
We may refuse to proceed the transaction of transferring the purchased NFTs to the User if the User refuses to provide any demanded information. We may refuse to issue tokens to the User if:
a. The User does not provide any demanded information to us and enables to complete any diligence procedures on the User;
b. The User have been previously identified as engaged in suspicious activity;
c. The User is the citizen or resident of a country considered to be exposed to a high risk of money laundering or financing terrorism including but not limited to Cuba, Iran, North Korea, Sudan, Afghanistan or Syria or any other country as may from time to time be subject to United States or European Union embargo, UN sanctions, HM Treasury’s financial sanctions regime;
d. The User is listed on a sanctions list in any of the jurisdictions to which we may transfer purchased tokens (including but not limited to Specially Designated Nationals And Blocked Persons List), or we otherwise identify the User as exposed to a high risk of money laundering or financing terrorism.
1.8. Payment cancellation.
The User cannot cancel a request to purchase NFTs tokens. If the User is not able to provide sufficient information to proof his or her identity, we may cancel the User’s requested transaction with or without a refund.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by us, whose duty is to ensure the effective implementation and enforcement of the AML and KYC Policy.
It is the Compliance Officer’s responsibility to supervise all aspects of our anti-money laundering and counter-terrorist financing, including but not limited to:
a. Collecting User’s identification information;
b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
c. Monitoring transactions and investigating any significant deviations from normal activity;
d. Implementing a record management system for appropriate storage and retrieval of documents, files, forms and logs;
e. Updating risk assessment regularly;
f. Providing law enforcement with information as required under the applicable laws and regulations.
2.3 Law enforcement
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
2.4 Contact with the clients and authorities
The Compliance Officer is obliged to communicate effectively with the clients and authorities having any complaints or questions that are being addressed to him regarding tour AML and KYC Policy as also its implementation in order to ensure the transparency and credibility of the platform.
3. Monitoring transactions
3.1 Data analysis
User verification is carried out not only by checking their identity, but also by analyzing transaction models. We therefore rely on data analysis as a tool for assessing risk and identifying suspicions. We carry out many regulatory compliance tasks, including data collection, filtering and record keeping.
3.2 Suspicious transactions reporting
With regard to the AML and KYC Policy, we will monitor all transactions, and it reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer and request the User to provide any additional information and documents in case of suspicious transactions. Compliance Officer will monitor User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Payment methods
4.1 Payment cards usage control
We may refuse to complete or block, cancel or reverse a transaction of the NFT tokens purchase made with payment cards usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action. We are under no obligation to disclose the details of its credit card risk management and security procedures to the User.
4.2 Transfer control
We may refuse to complete or block, cancel or reverse a transaction if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action.
4.3 Address analysis
We may analyze the purchaser addresses against common blacklists and known security discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money laundering (location, layers, integration), either manually or using a third-party service.
We have no control over, or liability for, the delivery, quality, safety and legality or any other aspect of any goods or services received or purchased.
5. Risk assessment
We, in accordance with international requirements takes a risk-based approach to combating money laundering and the financing of the terrorism. By applying a risk-based approach, we can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate with the identified risks. This makes it possible for resources to be allocated in the most efficient way. The principle is to allocate resources corresponding to priorities so that the highest risks are given the closest attention.
6. AML and KYC Policy