KYC Policy


What follows is a Policy that affects the relationship between You and SOCIALE DIGITAL (CYPRUS) LIMITED (Hereinafter- “SOCIALE”, “We”, “Us”, “Our”, or the “Company”).

International and local regulations require SOCIALE to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Clients.

To that end, we have developed the SOCIALE “Know Your Customer and Anti-Money Laundering Policy” (hereinafter- the “KYC/AML Policy” or simply, “Policy”). These key terms are defined as:

• Know your customer, alternatively known as “know your client” or simply “KYC”, is the process of a business verifying the identity of its clients and assessing potential risks of illegal intentions for the business relationship.

• Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.

The SOCIALE KYC/AML Policy is designed to lay down a framework to:

• Prevent SOCIALE from being used, intentionally or unintentionally, by criminal elements for money laundering or financing terrorist activities;

• Enable SOCIALE to know and understand its customers, clientele, contributors, and other contacts with which SOCIALE has any financial dealings with (collectively, “Clients”) and their financial background and source of funds better, which in turn would help it to manage its risks prudently;

• Put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws, procedures and regulatory guidelines; and

• Equip employees and contractors of SOCIALE with the necessary training and measures to deal with matters concerning KYC/AML procedures and reporting obligations.

The Policy is revisited periodically and amended from time to time based on prevailing industry standards and international regulations designed to facilitate the prevention of illicit activity including money laundering and terrorist financing. All senior management and employees of SOCIALE are required to acknowledge and be familiar with the Policy.

The SOCIALE KYC/AML Policy covers the following matters: Verification Procedures, Transactions Monitoring, Risk Assessment and Compliance Officer.

1. Verification Procedures

One of the international standards for preventing illegal activity is customer due diligence. Accordingly, SOCIALE establishes its own verification procedures within the standards of “Know Your Customer” frameworks.

1.1. Identity Verification

SOCIALE’s identity verification procedure requires its Clients to provide SOCIALE with reliable, authentic documentation, data and information (such as national ID, international passport, bank statements and utility bills), and SOCIALE reserves the right to collect Clients’ identification information for our KYC/AML Policy purposes.

SOCIALE will take steps to confirm the authenticity of documents and information provided by its Clients. All legal methods for double-checking identification information will be used and SOCIALE reserves the right to investigate any Clients who have been determined to be risky or suspicious.

SOCIALE reserves the right to verify Client’s identity on an on-going basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular customer). In addition, SOCIALE reserves the right to request up-to-date documents from individual Clients, even though they have passed identity verification in the past.

Customer identification information will be collected, stored, shared and protected strictly in accordance with the SOCIALE Privacy Policy and related regulations.

1.2. Card Verification

Clients who intend to use payment cards in connection with SOCIALE services have to pass card verification in accordance with instructions available on the SOCIALE Site.

2. Risk Assessment

SOCIALE, in accordance with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, SOCIALE is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

3. Monitoring Transactions

SOCIALE relies on data analysis as a risk-assessment and suspicion detection tool. We know our SOCIALE Clients not only by verifying their identity (who they are), but by analyzing their transactional patterns (what they do). SOCIALE does this by performing a variety of compliance-related tasks such as capturing and filtering data, keeping records, managing investigations and reporting.

The SOCIALE monitoring system functions by performing daily checks of Clients’ identities against recognized “black lists” such as the U.S. Department of Treasury’s Office of Foreign Asset Control, Specially Designated Nationals List, and the United Nations, European Union, UK Treasury sanctions lists, and by aggregating money transfers by multiple data points, placing Clients on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;

Monitoring all transactions to assure that:

• Transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;

• Clients are asked to provide additional information and documents in case of suspicious transactions;

• Customer accounts are suspended or terminated when SOCIALE reasonably suspects, in its sole discretion, that such customer is engaging or has engaged in illegal activity.

The SOCIALE Compliance Officer (described below) will monitor Clients’ transactions on a day-to-day basis in order to define whether such transactions are legitimate or suspicious enough to be reported.

4. Compliance Officer

The Compliance Officer is the person, duly authorized by SOCIALE, whose duty it is to assure the effective implementation and enforcement of the KYC/AML Policy. It is the Compliance Officer’s responsibility to supervise all aspects of SOCIALE’s identity verification and anti-money laundering efforts, including but not limited to:

• Collecting Clients’ identification information;

• Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;

• Monitoring transactions and investigating any significant deviations from normal activity. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;

• Updating risk assessment regularly;

• Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

Please bear in mind that SOCIALE may amend this KYC/AML Policy from time to time with or without prior notification to comply with US, Canada, United Kingdom and other applicable International and Local Legislation in the field of KYC and AML policies. We recommend you make it a habit to read this Policy from time to time, in the event changes have been made and the Policy is updated.