Cabinet

KYC Policy

CDD is a key measure to prevent money laundering and terrorist financing. ‘Know Your Customer’ (“KYC”) procedures are a critical element of managing financial crime risks. KYC procedures account for the entire customer relationship including account opening and related record-keeping, a customer acceptance policy and a tiered customer identification program that involves more extensive due diligence for higher risk accounts.

The extent of additional information needed, i.e. the need for extra identification and of any monitoring carried out in respect of any particular client or class/category of client, will depend on the money laundering or terrorist financing risk that the client, or class/category of client, is assessed to present to Eclipcoin.


1. Customer Due Diligence

CDD is required to verify a customer identity and comprise the risk profile of the customer. To complete CDD, at a minimum, Government Issued Identification Documentation must be obtained and verified against the information provided by the customer to complete their user profile. Verification of this information will be completed manually by employees, who will be provided with a sufficient level of training. Online video verification can be conducted in order to onboard potential customers and make sure they are indeed legitimate individuals. Additionally customer's selfie will be requested. Upon the request from FIU, eKYC systems offered by approved third-party providers can be implemented.

Additional information, such as proof of address documentation and/or source of funds/wealth questionnaires, may be requested if the customers risk rating requires such. This documentation shall, if required, be reviewed manually by Eclipcoin employees and checked against the documented requirements within the necessary process document(s).

Finally, should there be any doubt about the validation of the customer’s identity and/or address, EDD measures will be undertaken.

Employees must be fully satisfied as to the identity of every current/prospective Client with which Eclipcoin has entered, or shall enter, into a business relationship with.

Eclipcoin is required to ensure that it has adequate mechanisms in place in order to be in a position:

    • to determine who the applicant for business or any beneficial owner is;
    • to verify whether such person is who one purports to be;
    • to determine whether such person is acting on behalf of another person;
    • to establish the purpose and intended nature of the business relationship; and
    • to monitor such business relationship on an ongoing basis.

The Company’s CDD measures comprise of Collating of personal information upon registration/application of an account such as:

    • Full name (First name and Surname);
    • Date of Birth;
    • Full Address (including country);
    • Nationality;
    • Email Address; and
    • Mobile Telephone Number.


2. Risk Based Approach

In accordance with Financial Action Task Force (FATF) Recommendation 10 (Guidance H), Eclipcoin applies a risk-based approach to customer due diligence to ensure that heightened standards apply where higher risk exists and enable Eclipcoin to apply efficient measures where the risk is low.

The Eclipcoin Board of Directors, or where so delegated to its Compliance Officer, may designate specific products or circumstances of transactions into risk profiles and determine what CDD steps must be taken for these specific profiles.


3. Simplified Due Diligence

Eclipcoin does not permit access to any of its products or services unless CDD measures have been completed. Eclipcoin will apply CDD from 0, what includes the Proof of ID and Card Selfie submission prior to start any business relationship.

Identification of Individual Customers

The CDD procedures of Eclipcoin have the objective of assessing the risk associated with servicing specific customers by properly identifying the customer and determining, based on the risk assessment methodology, the customers risk rating.

To do so the Company will have to meet the following specific objectives for customer due diligence:

    • identification of a customer who is a natural person by collecting personal information sufficient to do such as for example names, address, and date of birth;
    • performing customer screening to identify individuals subject to sanctions or those that are considered to be PEP’s;
    • verification of the identity of customers when SDD is no longer applicable; and
    • ongoing verification of the personal information to ensure that the customer has correctly identified themselves.


4. Identity and Address Verification

The compliance team, under the supervision of the Compliance Officer, will designate specific identification and address verification documents or methodologies that are acceptable and in accordance with regulatory guidelines. In all situations, staff must only accept valid, current identification that meets the specified requirements as outlined in the KYC procedures, unless specifically advised by the Compliance Officer that another form of ID is acceptable.

Eclipcoin may engage with third parties to carry out, on their behalf, electronic verification of identity. These trustworthy third parties would be entrusted with carrying out the

verification of the customer´s identity on behalf of the Eclipcoin, such as capturing identity document information, a photo of the individual purporting to upload this information and/or performing address verification using established databases.

Eclipcoin will also confirm that the persons responsible for verification are informed about the requirements regarding the execution of the process. In addition, it must be ensured that the records are transmitted to Eclipcoin without delay. Based on the transmitted documents, Eclipcoin will examine whether the verification has been carried out properly. In particular, the improper execution of procedures may cast doubt on the trustworthiness of the third party.

Acceptable identity documents include:

• Current, valid Government-issued Passports;

  • Valid Government issued identification document such as driver's licence or identification card from a country of the European Union or a country that meets similar standards for the reliability and protection against forgery;
  • For non-resident aliens a work permit, resident card or other identification document issued by the host country
  • Acceptable Address Verification documents may vary between countries to include, but not limited to:

      • Bank Statement dated within the previous 3 months - must have some transactional activity and should not be printed from the internet
      • Utility bill or Utility statement dated within the previous 3 months: Gas, Electric, etc.
      • Council Tax bill dated within last 12 months
      • Government issued letter relating to tax, benefits dated within the last 3 months


    5. Failure to Identify an individual or a Corporate Customer

    Where Eclipcoin is unable to verify the identity of an applicant during the establishment of a business relationship, Eclipcoin will:

      • Not carry out any transaction through the account; and
      • Terminate the relationship.


    6. Escalations to the FIU

    Where there are indications for suspicious transactions, the Compliance Officer will file a report with the FIU. In instances where termination of the relationship may frustrate efforts of investigating a suspected money laundering or funding of terrorism operation the Compliance Officer may decide to put the termination process on hold to file a report to the Financial Intelligence Unit (“FIU”) as soon as reasonably possible and wait for consent from them.


    7. Enhanced Due Diligence

    Eclipcoin will apply, on a risk-based approach, enhanced customer due diligence measures in the circumstances and situations which, by their nature, can present a higher risk of money laundering or the funding of terrorism. The calculations used for identifying if an applicant is deemed to be High-Risk is detailed within the Customer's Risk assessment document.

    Eclipcoin may also apply enhanced due diligence procedures for customer’s that are transacting in high risk jurisdictions, with significant values, exchange volumes or have

    factor, i.e. they have been identified as a PEP. (This includes, but is not limited to, customers that are or may be PEPs and/or sanctioned individuals. In addition, customers performing large or complex transactions that cannot be explained when considering the client’s transaction history should also be subject to EDD) .

    As part of these additional measures, customers will also be required to provide us with a completed Source of Funds, Source of Wealth profile and Economic purpose of account use along with any documentation deemed necessary by the Compliance Department. Adverse Media checks, which are completed for all applicants regardless of their risk-rating, will also completed.

    Existing customers that were not identified as being High-Risk when their application was made could have their risk rating amended based on behaviours, transaction history or other alerts. In such instances, the EDD process will be applied to them.

    The ongoing AML monitoring will be introduced separately to expand on the measures against ML/TF.

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