Policy on Preventing Money Laundering and Terrorist Financing
Date of Last Revision: October 7th 2024
Innospace LTD is committed to forbidding and actively combating money laundering and any activities that enable money laundering or finance terrorist or criminal operations. Our policies, procedures, and internal controls for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) are designed to ensure adherence to all relevant laws.
1. AML Strategy Compliance
EU: Directive 2015/849 on preventing the financial system´s use for money laundering.
EU: Regulation 2015/847 concerning information on fund transfers.
EU: Various sanctions and measures against individuals and embargoes on specific goods, including dual-use items.
BE: The 2017 Law on money laundering prevention and cash use restriction.
2. Operational Guidelines
Upgrader rejects all cash purchases or redemptions.
Upgrader prohibits purchases by third parties, account management for others, and shared accounts.
Upgrader enforces strict documentation requirements without exceptions.
Upgrader does not permit peer-to-peer transfers.
Upgrader may refuse transactions under AML suspicion.
Under international law, we may report suspicious client activities without notification.
3. Customer Due Diligence Program / KYC Policy
Upgrader maintains rigorous Know-Your-Customer (KYC) standards, ensuring thorough identity checks and ongoing monitoring. We reserve the right to deny access for insufficient identity proof or suspected fraud, reporting any sanctioned or high-risk attempts to the Financial Intelligence Unit promptly.
High-risk customers, including Politically Exposed Persons (PEPs), their families, or associates, and individuals from countries deemed high-risk by the Financial Action Task Force, may undergo Enhanced Due Diligence. Failure to provide required identity verification within 30 days can lead to account denial or closure until compliance is achieved.
As part of our stringent Know Your Customer (KYC) protocols, we aim to verify the identities of our clients to prevent money laundering and terrorist financing. We employ systems and controls that meet regulatory standards and regularly update these systems to maintain their effectiveness.
4. Required Documentation
Our in-depth KYC assessments are particularly focused on any suspicious withdrawals and transactions. Should a user's transaction or withdrawal get marked as suspicious on our end, they may be required to provide:
Full name
Date of birth
Residential address
A government-issued ID (such as a passport, national ID card, or driver's license)
Proof of address (like a utility bill, bank statement, or another document that confirms their name and address)
A selfie with their ID document
Details for identity verification, including the user's country of residence, the purpose of transactions, and adherence to fair trading practices
In certain cases, when additional due-diligence is required, you may be required to have your documents notarised by a notary public.
5. Terms of Service Agreement
By setting up an account, you:
Agree not to use the service for illegal activities, such as laundering money, hiding its illegal origin, or supporting criminal actions.
Acknowledge that we may report your account details to authorities if necessary.
For our complete Terms of Service, please refer to upgrader.com/tos
6. Prohibited Services
Upgrader does not accept funds from, or allow transfers to, services involved in mixing cryptocurrencies or high-risk activities.
7. Monitoring for Suspicious Activity
We monitor all transactions for irregularities and report suspicious activities to authorities, potentially filing voluntary Suspicious Activity Reports (SARs).
Additionally, we encourage users to report any suspicious activity they encounter on our platform. If you observe potentially fraudulent or illegal behavior, you can report it by contacting our compliance team at [email protected]. We will investigate all reports confidentially and take appropriate action where necessary.
8. Compliance with International Sanctions
We ensure compliance with sanctions from bodies like the US OFAC, UK OFSI, EU, and UN, denying access to sanctioned individuals or entities and reporting any breaches.
9. Transfer of AML Information
We comply with law enforcement requests for information as required by law, cooperating with the Financial Intelligence Unit (FIU) as needed.
10. Data Security
We securely store user data, disclosing it only as legally required or to combat money laundering, in line with the General Data Protection Regulation (GDPR).
For detailed policies and guidelines, visit upgrader.com/tos
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Upgrader is operated by Innospace LTD, Organization number 646564, Voukourestiou, 25 Neptune House, 1st Floor, Office 11, Zakaki, 3045, Limassol, Cyprus.
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