ANTI-MONEY LAUNDERING POLICY

Vivaro Quadra OÜ (“we” or “our”) has developed an Anti-Money Laundering and counter terrorism financing Policy (“AML/CTF Program”) for our digital virtual currencies exchange, available at https://speedybits.net, in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in Estonia and the European Union and other countries where we conduct business. This includes, but is not limited to: Establishing robust internal policies, procedures and controls that combat any attempted use of Speedybits for illegal or illicit purposes and that are designed to ensure our customers basic protections under consumer protection laws; Maintaining comprehensive records of orders and other transfers; Executing Know Your Customer (“KYC”) procedures on all customers; Performing regular, independent audits of our AML/CTF Program; and Implementing a formal and ongoing compliance training program for all new and existing employees.

GENERAL

Speedybits does not tolerate money laundering and supports the fight against money launderers.

Money laundering is the act of concealing the transformation of profits from illegal activities and corruption into ostensibly "legitimate" assets. Money laundering occurs when funds from an illegal/criminal activity are moved through the financial system in such a way as to make it appear that the funds have come from legitimate sources.

POLICIES AND PROCEDURES

We have adopted a risk-based approach during the customer due diligence procedures in line with the current AML/KYC regulations. Below you can find how we process the registration of customers` accounts, what information is collected and how it is verified.

Vivaro Quadra OÜ identifies the customer by obtaining a range of information about him/her. The verification of the identity consists of verifying some of this information against documents or information obtained from a reliable source which is independent of the customer. At least the following information must be received for identification purposes: name and surname; personal identity number (if such exists); date of birth; photograph on an official document which confirms his/her identity; residential address; the number of the personal identification document; the expiry date of the identification document.

Once a customer is identified and his/her identity is verified, Vivaro Quadra OÜ must conduct a certain level of due diligence based on a risk-based approach. For some business relationships, determined by the firm to present a low degree of risk of ML/TF, simplified due diligence (SDD) may be applied; in the case of higher risk situations, and specifically in relation to PEPs, enhanced due diligence (EDD) measures must be applied on a risk-sensitive basis.

Speedybits has policies in the field of counteraction of laundering money. These policies include:

  • ensuring clients have valid proof of identification;

  • requiring the client to provide valid utility bills for proof of residence;

  • maintaining records of identification information;

  • determining that clients are not offenders or terrorists by checking special lists;

  • informing clients that the information they provide may be used to verify their identity;

  • following clients’ money transactions;

  • maintaining records of identification information.

The AML measures which the Company generally will take:

  • collect sufficient information from each Customer who has opened an account to enable the Customer to be identified;

  • utilize risk-based measures to verify the identity of each Customer who has opened an account;

  • record Customers’ information and the verification methods and results; provide the required adequate notice to Customers that we will seek identification information to verify their identities;

  • compare Customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.

CUSTOMER IDENTIFICATION

The KYC process is an important part of our AML/CTF Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

Account opening process:

In order to open an account and use Speedybits, your identity must be verified, authenticated, and checked against governmental watch lists. Failure to complete any of these steps will result in your inability to use our Services.

Individual customer — Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information: Email address; Mobile phone number; Full legal name; Tax ID Number; Date of birth (“DOB”); Occupation; Proof of identity (e.g., driver’s license, passport); Home address (not a mailing address or P.O. Box); and Additional information or documentation at the discretion of our Compliance Team, such as utility bills or bank account statements. If you successfully meet and complete our KYC requirements and do not appear on any government watch list, then we will provide you with account opening agreements electronically.

Corporate customer — Prior to opening an account for an corporate customer, we attempt to collect, verify, and authenticate the following information: Company’s legal name; Registered company number; Full legal name (of all account signatories and beneficial owners); Email address (of all account signatories); Mobile phone number (of all account signatories); Address (principal place of business and/or other physical location); Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable); Contract information of owners, principals, and executive management (as applicable); Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 25% or more, as well as all account signatories; and Identifying information for each entity beneficial owner that owns 25% or more (see individual customer information collected above for more details). If your institution successfully meets and completes our KYB requirements and neither it nor any of its owners, principals, executive, or managers appear any governmental watch list, we will provide you with account opening agreements electronically.

SUSPICIOUS ACTIVITY/ CURRENCY TRANSACTION REPORTS

Broad categories of reason for suspicion and examples of suspicious transactions are indicated as under: 

Identity of client:

a) False identification documents.

b) Identification documents which could not be verified within reasonable time.

c) Accounts opened with names very close to other established business entities.

d) Background of Client: suspicious background or links with known criminals.

e) Multiple Accounts: large number of accounts having a common account holder.

Activity in accounts:

a) Unusual activity compared with past transactions.

b) Sudden activity in dormant accounts.

Nature of transactions:

a) Unusual or unjustified complexity;

b) No economic rationale or bonafide purpose;

c) Nature of transactions inconsistent with what would be expected from particular Customer.

We may freeze or suspend your account, as well as report to applicable authorities, if we know, suspect or have reason to suspect suspicious activities have occurred on Speedybits. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our compliance team reviews and investigates suspicious activity to determine if sufficient information has been collected to justify any action from our side.

RECORDS KEEPING

All records are retained for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.