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AML & KYC POLICY

It is the policy of Hartmann & Benz, LLC to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership, and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money, and the associated transactions may not be complex.

Hartmann & Benz, LLC’s KYC & AML policies, procedures, and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated regularly to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

Our AML Program shall be kept in writing. We will make copies of our AML Program available for inspection to the Department of the Treasury upon request. Specific provisions of our policies are confidential and for internal use only in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce some general rules and stipulations of our policies that directly concern you and affect the services we render.

USER’S IDENTIFICATION

In the first place, we are obliged to identify, beyond a reasonable doubt, identity of persons enabled to buy and sell tokens from our Company. This is the reason why we collect ID scans, which authenticity is verified with special software of professional external providers.

We require sending a “selfie” or your recording with an ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made with the use of special software of professional external providers or, in case of doubts, done manually by our customer support services.

In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arise.

In addition, we perform enhanced due diligence when a user is deemed at higher risk than expected. These high-risk users normally include Politically Exposed Persons or anyone originating from high-risk countries, as outlined in the Fifth Anti-Money Laundering Directive. Enhanced due diligence measures usually include high monitoring of users. 

If we cannot determine, beyond a reasonable doubt, that the documents you provided

belong to you and are authentic, we won’t be able to let you purchase or sell the Tokens.

USER’S IDENTIFICATION – COMPANIES

In the case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company.

Since standards regarding governmental documentation of legal entities are different in each countries, every time, the verification of such users is done “manually” and is considerably more time-consuming.

TRANSACTIONS’ MONITORING AND SUPERVISION

Using our proprietary software, we also analyze all transactions that take place on our Website, looking for suspicious and unusual behaviours. Such selected transactions are analysed by our AML specialists and evaluated if they do not provide significant AML / CTF risks or if they need to be ceased and clarified with the User.

ADDITIONAL VERIFICATION

When your trade volume rises, our AML / CTF verification duties also increase. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk.

In such cases, we can require additional documentation proving your real, exact place of residence, education, and occupation, as well as the source of money you are using on the exchange.

Unfortunately, If our AML specialists decide information received from you doesn’t clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to the relevant authorities.

BASIC AM / CTF RULES

Our operating rules include inter alia as follows:

  1. The Company does not accept cash deposits or cash withdrawals in any cases.
  2. The Company does not accept any third parties’ deposits on the user’s account, managing the account on behalf of somebody, joint or shared accounts, etc.
  3. The Company does not allow any exceptions in the field of documentation required from users.
  4. The Company reserves the right to refuse to process the Users purchase of Tokens at any time in case of suspicion of AML / CTF risk.
  5. In accordance with international law, we are not obliged (or even forbidden) to inform our clients if we report their behaviors as suspicious to relevant authorities.

SANCTION CHECKS

Individuals or institutions that do not comply with laws and rules are served with penalties, and these penalties are called sanctions. Usually, the sanction decisions are made by governments or global regulators. We carry out sanction checks from a list of different governmental and international databases to identify persons banned from certain activities or sectors. Political exposure, terrorism, money laundering, and corruption are the most popular reasons for sanctions. We verify that the customer we are dealing with isn’t on any of the sanction lists, and this process should be ongoing because sanctions lists are updated regularly.

KYC VERIFICATION 

When a user purchases a large number of Tokens, it raises AML / CTF risk. That is why we have to introduce proper safety and verification duties. Currently, our KYC / AML verification model is:

Level 1

Available Purchase/Withdrawal Methods: USD, BTC, and ETH

Purchase Limited: Unlimited

Withdrawal Limited: $1,000 daily up to $5,000 monthly.

KYC: ID verification and Address verification

Level 2

Available Purchase/Withdrawal Methods: USD, BTC, and ETH

Purchase Limited: Unlimited

Withdrawal Limited: $5,000 daily up to $20,000 monthly.

KYC: Utility Bill, Bank Statement

Level 2

Available Purchase/Withdrawal Methods: USD, BTC, and ETH

Purchase Limited: Unlimited

Withdrawal Limited: Unlimited

KYC: Source of funds, source of wealth, Video verification

The model above is a result of the work and experience of our AML team and can be changed as legal requirements of countries change as well as a result of gaining new knowledge and experience.