1. General provision

1.1. The AML/KYC policy (hereinafter – the policy) establishes the General principles of identification of Users – individuals and legal entities with participation in the ICO by InnovaMinex (hereinafter – The Company). The policy establishes requirements aimed at the identification and analysis of customers ' activities in order to prevent the company's interaction with persons engaged in activities related to the legalization of proceeds from crime and the financing of terrorism.

1.2. The policy is developed in accordance with the norms of international legislation on the prevention of criminal activities related to money laundering and the financing of terrorism.

The policy is applied at the time of registration of the Client in the personal account and continues until the complete cessation of interaction with the Company.


2. The KYC (know your customer) policy

2.1. The Client undertakes to undergo the KYC procedure when registering the Client in the personal account, which consists in providing relevant identification information and notifying the company of changes in contact or personal data within 10 (ten) calendar days from the date of their changes.

2.2. Identification of individuals involves the following information: name, country of residence, registration address, telephone number, as well as an indication that the person is not an official. Identification of individuals involves the provision of the following documents: passport scan, photo, scan of the document certifying the address of residence of the Client. At the same time, in order to verify the accuracy of the Client's address, the Company requires that one of the following documents: a scan of the utility bill (landline phone, water, electricity) of high resolution for the last 3 months; a copy of the tax or tariff account from the local authority; a copy of the account statement (for the current account, Deposit account or credit card account); copy of Bank reference letter. If a person makes a transaction in the amount of more than 10000 euros, it must indicate the essence of the transaction, the reasons for its Commission, confirm the intention of the transaction.

2.3. Identification of legal entities involves the following information: name, legal form, registration address, registration number, name of the person acting on behalf of the person, phone number, e-mail address. Identification of legal entities involves the provision of the following documents:

1. Document confirming the existence of a legal entity (usually an extract from the register):

The document should contain the following data:

  • Name of legal entity
  • Registration number
  • Jus. Address
  • Form corporate-owned devices


2. Document confirming the authority of the person who performs actions on behalf of the legal entity. In this case, it can play the role of an extract from the register, from which contain the names of Directors, the Charter of the company, from which the powers of Directors, the power of attorney are visible. The document should contain data on the powers and terms of authority.

3. List of founders-a document from which you can draw a conclusion about the structure of the company and its founders. With respect to the founders, who have 25% or more of the participation share held KYC as for individuals in respect of others, enough basic data from the register statement. If a person makes a transaction in the amount of more than 10000, he must indicate the essence of the transaction, the reasons for its Commission, confirm the intention of the transaction.


3. The AML policy

3.1. The company has a zero tolerance policy for money laundering activities. We define money laundering as any activity that attempts to distort the source of funds actually acquired through illegal processes as funds that have been acquired through legitimate sources / activities.

3.2. Customers (including buyer of tokens) acknowledge, undertake and agree to the following terms regarding the use of their tokens to open and service accounts in InnovaMinex for all financial transactions as a client

1) the Client will comply (for as long as he is a client of the Company) with all relevant provisions relating to money laundering and proceeds of crime.

2) the Client agrees to provide full assistance to the Company in relation to anti-money laundering efforts. This includes all information that the Company requests in relation to the business customer data, account usage, financial transactions, etc., to help the Company to perform their duties, as dictated by applicable laws, regardless of jurisdiction.

3) the Company reserves the right to delay or terminate any transfer of funds if there is reason to believe that the completion of such transaction may violate any applicable law or practice.

4) the Company reserves the right to suspend or terminate any account or freeze funds in the account if there is reason to believe that the account is being used for activities that are deemed illegal or fraudulent.

5) the Company has the right to use information about the client to investigate and / or prevent fraudulent or other illegal actions.

6) Activities that the Company considers possible indicators of money laundering include:

1) the Buyer (for all the time since he became a Client) expresses unusual concerns or reservations about the anti-money laundering policy in the Company.

2) the Client is interested in financial transactions that are contrary to the common sense of business or incompatible with the client's business policy.

3) the Client can not provide information about the legality of the sources of their funds.

4) the Client provides false information about the source of his funds.

5) the Client appears in the stories or in the news, indicating civil or criminal offenses committed by him.

6) The client cannot easily describe the nature of his activity.

7) the Client often makes large deposits of funds, as well as forms applications using only cash.

8) the Customer maintains multiple accounts and conducts an unusually large number of transactions between their accounts or to accounts of third parties.

9) there is a surge in the activity of transfers, on the client's account, usually not previously active.

3.3. The above list is by no means exhaustive. The company monitors the activities of its clients and their accounts in the light of a number of other problems and takes appropriate measures to prevent money laundering.


4. Restrictions on operations

4.1. The company does not open accounts for anonymous owners (i.e. without providing primary information when registering the Client in the personal account).

4.2. Each client undertakes to carry out operations individually and independently. In case of voluntary transfer of account management or trading accounts to third parties, the Client undertakes to notify the company and provide documents for the identification of these persons, as well as documents granting the right to use the account by these third parties. In case of failure to provide such documents, the Company reserves the right to:

  • Cancel all or several transactions
  • Review the amount of funds available for withdrawal
  • Suspend service of one or more crypto wallets
  • Block access to your personal account
  • Terminate all existing contracts and agreements

4.3. The company continuously monitors clients ' transactions in order to timely identify suspicious transactions among them, as well as transactions. subject to mandatory control.


5. KYC/AML compliance officer

5.1. The Supervisory officer is a person duly authorized by the Company whose responsibility it is to ensure the effective implementation and enforcement of the AML / KYC policy.

5.2. It is the responsibility of the Supervisory officer to monitor all aspects of anti-money laundering and anti-terrorist financing in the Company, including but not limited to:

  • Collection of user identification information
  • Create and update internal policies and procedures to complete, review, submit and maintain all data and reports required by applicable laws and regulations.
  • Transaction monitoring and investigation of any significant deviations from normal activities.
  • Implementation of records management system for appropriate storage and search of documents, files, forms and journals.
  • Regular updating of the risk assessment.
  • Providing law enforcement authorities with information required by applicable laws and regulations.

5.3. A member of the Supervisory service has the right to interact with law enforcement agencies that are engaged in activities to prevent money laundering, terrorist financing and other illegal activities


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