- 1.1The Website of cryptogt.com is owned and operated by Hatio Ltd. Hatio Ltd (the ‘Company’) is an International business company with registration number 90645.
- 2.1 The AML & KYC Policy (the ‘Policy’) is provided by the Company to its Clients in order to help them to understand the rules and the procedures followed by the Company in order to comply with the anti- money laundering and terrorist financing laws, as well as Know-Your-Client requirements.
3. Anti - Money Laundering (AML) Policy
- 3.1The Prevention of money laundering and terrorist financing is a major responsibility and aim of the Company. The Company is fully committed to prevent any money laundering activities through its services and as such, in the Company’s efforts to combat money laundering, we ensure that the Company:
- 3.1.1Gets to know its Clients through request of legal documentation
- 3.1.2Identifies and report any suspicious transactions through the appropriate channels
- 3.1.3Carries on an on-going monitoring of any reported suspicious activities
- 3.1.4Maintains all transaction records of Clients for a minimum of 5 years, following termination of the Agreement
- 3.1.5 Ensures that all staff is sufficiently trained in the appropriate KYC and AML procedures as well as in what constitutes suspicious activity and to reporting such activity to the appropriate personnel.
- 3.1.6 Uses all resources available, within the Company’s and other countries to ensure that all suspicious activities have been investigated
- 3.2The Company reserves the right to request all necessary Verification Documents from the Client before the expiry of the Probation Period, described in the Commencement of the Terms and Conditions and the Right to Cancel section of the Client’s Agreement. Additionally, the Company reserves the right to request additional or updated documentation, if it deems as necessary.
- 3.3 The Company reserves the right to refuse to process a transfer at any stage if it believes/suspects it to be connected in any way to criminal activity or money laundering.
- 3.4The Company is obliged to report all suspicious transactions to the relevant authorities and is prohibited from informing the Client that they have been reported for suspicious account activity. Account misuse may result in criminal prosecution.
- 3.5The Company is strongly opposed on providing business to Clients whose funds are sourced from criminal activity.
- 3.6.1The electronic monitoring of transactions is an issue that is receiving a great deal of attention by the financial services industry. More and more transactions are being undertaken electronically, without any human intervention, providing those involved in money laundering with greater opportunities to launder money and to remain undetected.
- 3.6.2There is recognition by the industry and regulators that the electronic monitoring of transactions can provide some protection in dealing with this risk. A monitoring system can provide an effective way of identifying potential money laundering transactions.
- 3.6.3Transactions executed for the Client are compared and evaluated against the anticipated movement of the account, the standard turnover, business and customer data/information held and according to the economic profile of the customer. Significant deviations are investigated and the findings recorded in the file of the Client.
4. Know Your Customer (KYC) Procedures
- 4.1The Company has the right to request documents which confirm and verify the identity of a person who registers on the Company’s system and opens an account with the Firm. Hence, the Company will at times request from its Clients to provide certain Verification Documents (which shall typically include but not limited to, an identity card or passport, proof of residential address such as a recent utility bill, and sometimes a selfie will also be requested). Among other things, the following principles are considered as a part of the Know Your Customer procedure:
- 4.1.1The Company will not accept as Clients persons engaged in unethical behavior or in illegal activities.
- 4.1.2The Company will not accept as Clients, parties that cannot make a well informed and reasonable judgment as to the activities in which they are engaged.
- 4.1.3The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information as requested.
- 4.1.4Document has to be valid
- 4.1.5Copy has to be in color (black and white copies are not acceptable)
- 4.1.6All information on the document must be clear and visible
- 4.2If, during the business relationship, a Client fails or refuses to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested the Company is entitled to terminate the business relationship and close all Client’s accounts. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If the Client denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship and close all Client’s Account(s), in compliance with the Termination and Default section of the Client’s Agreement.
- 4.3The Client warrants and represents that at all times all the information provided to the Company shall be true, accurate, up to date and complete and that the Client shall update the Company in writing via e-mail (send to the Company from the Client’s registered e-mail address) upon any changes in regard to the information provided.
- 4.5For deposit amounts of higher than 5,000 EUR, the client must submit the ‘Verification Documents’ during or upon account registration. For amounts below 5,000 EUR there is a probation period of fourteen (14) days in order to submit the ‘Verification Documents’, without the right to make any withdrawal from their account until the verification process is completed.
- Proof of the Client’s Residential Address* - In order to prove his/her residential address, the Client, if requested, is obliged to provide the Company with a copy of his/her recent Utility Bill (gas, water, electric, TV/Internet, landline phone) or a bank statement issued in his/her name. The issuing date of the document cannot be older than 3 months.