AML/KYC Policy

Introduction to AML/KYC Policy Nechangeo

Nechangeo Anti-Money Laundering and Know Your Customer Policy is designated to prevent and mitigate possible risks of Nechangeo being involved in any kind of illegal activity.

Nechangeo implement effective procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters at Nechangeo:

  1. Verification procedures.
  2. Compliance Officer.
  3. Monitoring All Transactions.
  4. Risk Assessment.

1. Verification steps

Nechangeo establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

Nechangeo identity verification procedure requires the User to provide Nechangeo with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Nechangeo reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Nechangeo will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Nechangeo reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Nechangeo reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious. In addition, Nechangeo reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected with the Nechangeo Privacy Policy .

Once the User’s identity has been verified, Nechangeo is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by Nechangeo, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Nechangeo’s anti-money laundering and counter-terrorist financing, including but not limited to:

a. Collecting Users’ 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 records 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.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

3. Monitoring All Transactions

The Users are known not only by verifying their identity but, more importantly, by analyzing their transactional patterns. Nechangeo perform capture data, filtering, record-keeping, investigation management, and reporting. System include:

1) Users recognized “black lists” where needed, sending internal communications and filling out statutory reports, if applicable;

2) Case and document management.

With regard to the AML/KYC Policy, Nechangeo 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;
  • request the User to provide any additional information and documents in case of suspicious transactions;
  • suspend or terminate User’s Account when Nechangeo has reasonably suspicion that such User engaged in illegal activity.

4. Risk Assessment

Nechangeo is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways.