Anti-money laundering (AML) and Know-your-customer (KYC)
processes
Money laundering is the process whereby the financial proceeds of a
crime are disguised to give the impression of legitimate income. Often criminals target
financial service providers through which they attempt to launder criminal proceeds without
raising suspicion. In many cases, laundered funds are used to fund further crime or to
finance terrorism. Sometimes both.
As a means to combat money laundering and to counter terrorist
financing (CTF), most countries have implemented AML and CTF legislation which imposes
obligations on financial service providers. Although it is not always clear in some of our
countries, where we have a presence, whether these obligations fall on cryptocurrency
providers, these laws, together with guidance from regulators, applicable task forces and
industry best practice, form the cornerstone of Virarosi’s approach to AML and CTF. As
such, Virarosi has implemented systems and controls that meet the standards applicable to
regulated sectors such as banking. This decision reflects our desire to prevent money
laundering and terrorist financing.
Key components of our AML and CTF framework include the
following:
- The appointment of an independent risk committee which reports
to our board of directors regularly on all risk and compliance matters;
- The appointment of a Money Laundering Reporting Officer (MLRO).
This is an individual with a sufficient level of seniority and independence who is
tasked with the responsibility of overseeing compliance with the relevant legislation,
regulations, rules and industry guidance;
- Establishing and maintaining a risk-based approach to the
assessment and management of money laundering and terrorist financing risks;
- Establishing and maintaining a risk-based approach to Customer
Due Diligence (CDD), including customer identification, verification and KYC procedures.
To ensure we meet these standards, our customers are required to provide certain
personal details and documents when opening a Virarosi Account. The nature, and extent,
of what is required is guided by the customer’s deposit and withdrawal limits and,
in some cases, the customer’s country of residence. In certain circumstances,
Virarosi may perform enhanced due diligence procedures for customers presenting a higher
risk.
- Establishing and maintaining risk-based systems and procedures
for the monitoring of ongoing customer activity;
- Establishing procedures for reporting suspicious activity
internally and to the relevant law enforcement authorities as appropriate;
- Maintaining appropriate KYC records for the minimum prescribed
periods;
- Providing training on the framework and raising awareness among
all relevant employees;
- Designing systems and controls to allow Virarosi to comply with
all required sanction screening processes imposed by, for example, the United Nations,
European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) and to take
measures to prevent transacting with individuals, companies and countries appearing on
these sanctions lists.