AML Policy

Coinroom

Anti-Money Laundering and Anti-Terrorist Financing Policy

 

 

Table of contents:

  1. General 3

  1. Classification of Customers 2

  2. Identification 3

  3. Verification 4

  1. Objectives and organization of the control system 5

  2. Unsupported entities 7

  3. Role of the Management Board 13

  4. Miscellaneous 13

 

I. General

 

1. Pursuant to the requirements of the Act of 1 March 2018 on counteracting money laundering and terrorist financing (Journal of Laws of 2018 , item 723, 1075), hereinafter referred to as the “Act”, Coinroom sp.
z o.o. is an obligated institution and is required to:

 

  1. act honestly, fairly, professionally and in the best interest of the Customer,

  2. provide accurate and complete information, i.e. such that is reliable, unambiguous and not misleading,

  3. provide Customers with services tailored to their individual needs and in accordance with the law provided for such services as virtual currency exchange and brokering in exchange, and consumer rights.

 

2. Coinroom sp. z o.o. does not operate any economic activity for the sale or support of investment processes involving the purchase/sale of virtual currencies. It is possible to purchase or sell a virtual currency via the coinroom.com website (hereinafter referred to as the “Website”).

 

A. Classification of Customers

 

1. Coinroom sp. z o.o. does not operate any classification of Customers other than that required under the Act regarding the application of financial security measures.

 

 

2. At the registration level, it is possible to set up an account for a natural person or a company (in the case of a company, it is required to provide the details of a person authorized to act on behalf of the Customer). The account is created for all Users. No anonymous use of the Website is permitted.

 

B. Identification

 

1. Article 36. 1. of the Act stipulates that the identification of a Customer involves determining in the case of:

 

1) a natural person:

a) name and surname,

b) citizenship,

c) number of the Universal Electronic System for Registration of the Population (PESEL) or date of birth in the case if the PESEL number has not been assigned, and the state of birth,

d) series and number of the document confirming the identity of a person,

e) residence address in the case of availability of such information to the obligated institution,

f) name (company), tax identification number (NIP) and address of the principal place of business in the case of a natural person pursuing economic activity;

 

2) a legal person or an organizational unit without legal personality:

a) name (company),

b) organisational form,

c) address of the registered office or address of pursuing the activity,

d) NIP, and in the case of unavailability of such a number – the state of registration, the commercial register as well as the number and date of registration,

e) identification data referred to in subparagraph 1 (a) and (c) of a person representing such legal person or organizational unit without legal personality.

 

2. The identification of the beneficial owner comprises determining of the data referred to in paragraph 1 (1) (a) and (b) in the case such information is held by the obligated institution, including the data referred to in paragraph 1 (1) (c)-(e).

 

3. The identification of a person authorized to act on behalf of the Customer comprises determining of the data referred to in paragraph 1 (1) (a)-(d).

 

 

C. Verification

 

1. Article 37 of the Act stipulates that the verification of identity of a Customer, a person authorized to act of its behalf and the beneficial owner must be based on confirmation of determined identification data based on a document confirming the identity of a natural person, a document containing valid data from the extract of the relevant register or other documents, data or information originating from a reliable and independent source.

 

2. Article 34.4 of the Act stipulates that Coinroom sp. z o.o. as an Obligated Institution may, for the purpose of applying financial security measures, process information contained in the identity documents of a Customer and a person authorized to act on its behalf and make copies thereof.

 

3. In view of the above, the system provides the following functionalities:

  1. file upload (ID card scan),

  2. file approval mechanism by an authorized employee.

 

4. Moreover, the following measures are applied in accordance with the agreements reached at the level of accepted standards for Anti-Money Laundering (AML) and Know Your Customer (KYC):

 

  1. each user is identified,

  2. transaction are monitored in accordance with the analysis and execution of occasional transactions within the meaning of the Act. For amounts equal to or exceeding EUR 15,000, the verification is mandatory and the execution of a transaction is blocked until approval,

  3. a bank transfer is rejected if the operator deems it necessary and reasonable to meet the requirements of the Act,

  4. a bank transfer is suspended until clarification with the Customer.

 

5. Employees are adequately trained in AML and ATF procedures.

 

 

II. Objectives and organization of the control system

 

1. The internal control system comprises a set of control policies, procedures, mechanisms and activities, embedded in a sustainable and consistent manner in the risk management system, linked to strategic goals, supporting the achievement of business objectives and enabling supervision over the activities of Coinroom sp. z o.o.

 

2. The purpose of the internal control system is to ensure:

  1. effectiveness and efficiency of operations of Coinroom sp. z o.o.

  2. reliability of financial reporting,

  3. adherence to risk management principles,

  4. compliance of the bank’s operations with the law, internal regulations and market standards.

 

3. The internal control system consists of:

  1. Control Function, whose responsibility is to ensure compliance with control mechanisms in the processes operated at Coinroom Sp. z o.o., including risk management,

  2. Compliance Department, whose responsibility is to identify, assess, control and monitor the non-compliance risks, to perform assessments and reporting related to the fulfilment of the obligations under the Act, including for suspicious transactions,

  3. employees of the Anti-Money Laundering Department, whose responsibility is to monitor, approve and report on activities.

 

4. Coinroom sp. z o.o. documents the financial security measures applied and the results of the ongoing analysis of transactions completed. At the request of the authorities referred to in Article 130 of the Act, Coinroom discloses the same while indicating that, taking into account the level of recognized risk of money laundering and terrorist financing related to a business relationship or an occasional transaction, appropriate financial security measures have been applied.

 

5. Coinroom monitors exchange transactions with a view to analyzing the risk to coordinate activities aimed at risk assessment and application of measures aimed at effective mitigation thereof. Based on this analysis, Coinroom applies a risk-based approach to ensure that the measures taken to prevent or reduce the risk of money laundering or terrorist financing are appropriate to the risks identified. In the case of risk analysis leading to the determination that cash for which a Customer makes an exchange transaction may come from a crime, the Service Provider does not effect the exchange or immediately cancels the exchange at the risk and expense of the Customer.

 

6. The Control Function comprises:

    1. control mechanisms embedded in the processes operated on the Website,

    2. independent monitoring of compliance with these control mechanisms,

    3. reporting as part of the control function.

 

 

 

 

 

 

 

III. Unsupported entities

 

1. Unsupported entities are those entered into the following lists:

 

  1. European Union sanction lists and programmes, available at:

 

  1. Office of Foreign Assets Control (OFAC) sanction lists and programmes

 

  1. UN sanctions lists, available at:

 

 

2. Coinroom sp. z o.o. does not provide services to citizens of: Russian Federation, People’s Republic of China and citizens of the United States of America.

 

3. Moreover, Coinroom sp. z o.o. abides by the regulations adopted by the Council of the European Union in relation to individual countries:

 

Iran

COUNCIL REGULATION (EU) No 359/2011 of 12 April 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran

COUNCIL REGULATION (EU) No 267/2012 of 23 March 2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010, as amended

COUNCIL REGULATION (EU) No 708/2012 of 2 August 2012 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran

COUNCIL REGULATION (EU) No 1263/2012 of 21 December 2012 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran

 

Sudan

COUNCIL REGULATION (EC) No 131/2004 of 26 January 2004 imposing certain restrictive measures in respect of Sudan and South Sudan.

COUNCIL REGULATION (EC) No 838/2005 of 30 May 2005 amending Regulation (EC) No 131/2004 concerning certain restrictive measures in respect of Sudan

COUNCIL REGULATION (EC) No 1184/2005 of 18 July 2005 imposing certain specific restrictive measures directed against certain persons impeding the peace process and breaking international law in the conflict in the Darfur region in Sudan

COUNCIL REGULATION (EU) No 1215/2011 of 24 November 2011 amending Regulation (EC) No 131/2004 concerning certain restrictive measures in respect of Sudan

 

Burma

REGULATION (EC) No 194/2008 of 25 February 2008 renewing and strengthening the restrictive measures in respect of Burma/Myanmar and repealing Regulation (EC) No 817/2006

COUNCIL REGULATION (EU) No 409/2012 of 14 May 2012 suspending certain restrictive measures laid down in Regulation (EC) No 194/2008 renewing and strengthening the restrictive measures in respect of Burma/Myanmar

COUNCIL REGULATION (EU) No 401/2013 of 2 May 2013 concerning restrictive measures in respect of Myanmar/Burma and repealing Regulation (EC) No 194/2008

 

Syria

COUNCIL REGULATION (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011

COUNCIL REGULATION (EU) No 168/2012 of 27 February 2012 amending Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria

COUNCIL REGULATION (EU) No 867/2012 of 24 September 2012 amending Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria

 

North Korea

Council Regulation (EC) No 329/2007 of 27 March 2007 concerning restrictive measures against the Democratic People’s Republic of Korea

COUNCIL REGULATION (EC) No 117/2008 of 28 January 2008 amending Regulation (EC) No 329/2007 concerning restrictive measures against the Democratic People’s Republic of Korea

COUNCIL REGULATION (EU) No 1283/2009 of 22 December 2009 amending Regulation (EC) No 329/2007 concerning restrictive measures against the Democratic People’s Republic of Korea

 

Ukraine/Russia and the territory of Crimea

COUNCIL REGULATION (EU) No 208/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine

COUNCIL REGULATION (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

COUNCIL REGULATION (EU) No 284/2014 of 21 March 2014 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

COUNCIL REGULATION (EU) No 692/2014 of 23 June 2014 concerning restrictions on the import into the Union of goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea and Sevastopol

COUNCIL REGULATION (EU) No 783/2014 of 18 July 2014 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

COUNCIL REGULATION (EU) No 825/2014 of 30 July 2014 amending Regulation (EU) No 692/2014 concerning restrictions on the import into the Union of goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea and Sevastopol

COUNCIL REGULATION (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine

COUNCIL REGULATION (EU) No 960/2014 of 8 September 2014 amending Regulation (EC) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine

COUNCIL REGULATION (EU) No 961/2014 of 8 September 2014 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

COUNCIL REGULATION (EU) No 1290/2014 of 4 December 2014 amending Regulation (EC) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine and amending Regulation (EU) No 960/2014 amending Regulation No 833/2014

COUNCIL REGULATION (EU) No 1351/2014 of 18 December 2014 amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol

 

Iraq

COUNCIL REGULATION (EC) No 1210/2003 of 7 July 2005 concerning certain specific restrictions on economic and financial relations with Iraq and repealing Regulation (EC) No 2465/96

COUNCIL REGULATION (EU) No 131/2011 of 14 February 2011 amending Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq

 

Libya

COUNCIL REGULATION (EU) No 204/2011 of 2 March 2011 concerning restrictive measures in view of the situation in Libya

COUNCIL REGULATION (EU) No 296/2011 of 25 March 2011 amending Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya

COUNCIL REGULATION (EU) No 572/2011 of 16 June 2011 amending Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya

COUNCIL REGULATION (EU) No 965/2011 of 28 September 2011 amending Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya

COUNCIL REGULATION (EU) No 1360/2011 of 20 December 2011 amending Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya

 

Belarus

COUNCIL REGULATION (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus

COUNCIL REGULATION (EC) No 646/2008 of 8 July 2008 amending Regulation (EC) No 765/2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus

COUNCIL IMPLEMENTING REGULATION (EU) No 84/2011 of 31 January 2011 amending Regulation (EC) No 765/2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus

COUNCIL REGULATION (EU) No 999/2011 of 10 October 2011 amending Regulation (EC) No 765/2006 concerning certain restrictive measures in respect of Belarus

COUNCIL REGULATION (EU) No 114/2012 of 10 February 2012 amending Regulation (EC) No 765/2006 concerning certain restrictive measures in respect of Belarus

COUNCIL REGULATION (EU) No 354/2012 of 23 April 2012 amending Regulation (EC) No 765/2006 concerning certain restrictive measures in respect of Belarus

 

Democratic Republic of Congo and Rwanda

COUNCIL REGULATION (EC) No 1183/2005 of 18 July 2005 imposing certain specific restrictive measures directed against persons acting in violation of the arms embargo with regard to the Democratic Republic of the Congo

 

Lebanon

COUNCIL REGULATION (EC) No 305/2006 of 21 February 2006 imposing specific restrictive measures against certain persons suspected of involvement in the assassination of former Lebanese Prime Minister Rafiq Hariri

 

Liberia

COUNCIL REGULATION (EC) No 234/2004 of 10 February 2004 concerning certain restrictive measures in respect of Liberia and repealing Regulation (EC) No 1030/2003

COUNCIL REGULATION (EC) No 872/2004 of 29 April 2004 concerning further restrictive measures in relation to Liberia

 

Sierra Leone

COUNCIL REGULATION (EC) No 303/2002 of 18 February 2002 concerning the importation into the Community of rough diamonds from Sierra Leone

 

Somalia

COUNCIL REGULATION (EU) No 356/2010 of 26 April 2010 imposing certain specific restrictive measures directed against certain natural or legal persons, entities or bodies, in view of the situation in Somalia

 

Côte d’Ivoire

COUNCIL REGULATION (EC) No 174/2005 of 31 January 2005 imposing restrictions on the supply of assistance related to military activities to Côte d’Ivoire

COUNCIL REGULATION (EC) No 560/2005 of 12 April 2005 imposing certain specific restrictive measures directed against certain persons and entities in view of the situation in Côte d’Ivoire

COUNCIL REGULATION (EU) No 25/2011 of 14 January 2011 amending Regulation (EC) No 560/2005 imposing certain specific restrictive measures directed against certain persons and entities in view of the situation in Côte d’Ivoire

COUNCIL REGULATION (EU) No 330/2011 of 6 April 2011 amending Regulation (EC) No 560/2005 imposing certain specific restrictive measures directed against certain persons and entities in view of the situation in Côte d’Ivoire

COUNCIL REGULATION (EU) No 668/2011 of 12 July 2011 amending Regulation (EC) No 174/2005 imposing restrictions on the supply of assistance related to military activities to Côte d’Ivoire

 

Afghanistan and Al-Qaida

COUNCIL REGULATION (EC) No 881/2002 of 27 May 2002 imposing certain specific restrictive measures directed against certain persons and entities associated with Usama bin Laden, the Al-Qaida network and the Taliban, and repealing Council Regulation (EC) No 467/2001 prohibiting the export of certain goods and services to Afghanistan, strengthening the flight ban and extending the freeze of funds and other financial resources in respect of the Taliban of Afghanistan

COUNCIL REGULATION (EC) No 561/2003 of 27 March 2003 amending, as regards exceptions to the freezing of funds and economic resources, Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with Usama bin Laden, the Al-Qaida network and the Taliban

COUNCIL REGULATION (EU) No 753/2011 of 1 August 2011 concerning restrictive measures directed against certain individuals, groups, undertakings and entities in view of the situation in Afghanistan

COUNCIL REGULATION (EC) No 754/2011 of 1 August 2011 amending Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with Usama bin Laden, the Al-Qaida network and the Taliban

 

Zimbabwe

COUNCIL REGULATION (EC) No 314/2004 of 19 February 2004 concerning certain restrictive measures in respect of Zimbabwe

Central African Republic

COUNCIL REGULATION (EU) No 224/2014 of 10 March 2014 concerning restrictive measures in view of the situation in the Central African Republic

 

 

 

IV. Role of the Executive Board

 

1. The Management Board of Coinroom sp. z o.o. is responsible for designing, implementing and ensuring the operation of an effective system of controlling compliance with the Act and internal regulations concerning fraud, including counteracting money laundering and terrorist financing, in all organizational units, organizational departments and organizational positions.

 

2. The Management Board establishes and periodically updates the criteria for assessing the effectiveness of the control system, criteria for identifying significant processes and rules for categorizing irregularities detected by the control system.

 

3. The Management Board defines the principles of periodic reporting of irregularities detected by the control system and the status of corrective actions taken.

 

4. The Management Board ensures a regular review of all processes operated in Coinroom sp. z o.o. in terms of their significance.

 

  1. Miscellaneous

1. The detailed rules for the operation of Coinroom sp. z o.o. and the ICT systems are covered by the business secret.

 

2. Coinroom sp. z o.o. cooperates with law enforcement agencies and the supervisory authorities in accordance with the Act as regards the exchange of information under the law, in particular in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation/GDPR) (OJ EU L 119 of 2016, pp. 1-88).

 

3. In case of any inquiries related to the Anti-Money Laundering and Know Your Customer Policy, please contact us by mail at the address:

 

Centrum Finansowe Okęcie,

Coinroom Sp. z o.o.

Ul. Janka Muzykanta 60,

02-188 Warsaw

 

or

 

4. Company details:

Coinroom sp. z o.o., ul. Janka Muzykanta 60, 02-188 Warsaw, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS 0000621487, VAT No.: 5272771777, REGON: 364625784, share capital PLN 100,000 paid-up in full (registered office of the organization).