WE FINANCE CLUB LIMITED’s Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) aims to prevent and mitigate the potential risks of WE FINANCE CLUB LIMITED being involved in any type of illicit activity.
Both international and local regulations require WE FINANCE CLUB LIMITED 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 act on any form of suspicious activity by its Users.
Our AML/KYC policy covers the following sections, which will be further developed in subsequent paragraphs:
– Verification procedures.
– AML Compliance Officer.
– Transaction monitoring.
– Risk assessment.
1. Verification procedures.
One of the international standards for preventing illegal activity is customer due diligence (CDD). In accordance with CDD, WE FINANCE CLUB LIMITED establishes its own verification procedures within the standards of the anti-money laundering and Know Your Customer (KYC) frameworks, including enhanced due diligence for higher risk customers such as Politically Exposed Persons (PEPs).
WE FINANCE CLUB LIMITED’s identity verification procedure requires the user to provide WE FINANCE CLUB LIMITED with reliable and independent documents, data or information (e.g. national identity card, international passport, electronic wallet number, fiscal and real address, photograph…). For such purposes, WE FINANCE CLUB LIMITED reserves the right to collect the user’s identification information for the purposes of the AML/KYC policy.
WE FINANCE CLUB LIMITED will take steps to confirm the authenticity of documents and information provided by Users. All lawful methods will be used to double check identification information and WE FINANCE CLUB LIMITED reserves the right to investigate certain Users who have been determined to be high risk or suspicious.
WE FINANCE CLUB LIMITED reserves the right to verify the identity of the User on an ongoing basis, especially when their identification details have changed or their activity appears suspicious (unusual for the particular User). Furthermore, WE FINANCE CLUB LIMITED reserves the right to request updated documents from Users, even if they have passed identity verification in the past.
Upon verification of the User’s identity, WE FINANCE CLUB LIMITED may disclaim any potential legal liability in a situation where its Services are used to conduct illegal activity.
WE FINANCE CLUB LIMITED is prohibited from transacting with persons, companies and countries on prescribed sanctions lists. WE FINANCE CLUB LIMITED will therefore check the sanctions lists of the United Nations, the European Union, the UK Treasury and the US Office of Foreign Assets Control (OFAC); as well as in all jurisdictions in which we operate.
2. AML Compliance Officer.
The AML (Anti-Money Laundering) Compliance Officer is the person, duly authorised by WE FINANCE CLUB LIMITED, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the responsibility of the AML Compliance Officer to oversee all aspects of WE FINANCE CLUB LIMITED’s anti-money laundering and combating the financing of terrorism, including, but not limited to:
– Collect user identification information;
– Establish and update internal policies and procedures for the completion, review, filing and retention of all reports and records required by applicable laws and regulations;
– Monitor transactions and investigate any significant deviations from normal activity;
– Implement a records management system for the proper storage and retrieval of documents, files, forms and records;
– Regularly update the risk assessment;
– Provide law enforcement with information as required by applicable laws and regulations.
The AML Compliance Officer is entitled to interact with law enforcement agencies, which are involved in the prevention of money laundering, terrorist financing and other illegal activities, as instructed by the UK Proceeds of Crime Act 2002 (“POCA”): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/317904/Fact_Sheet_-_Overview_of_POCA__2_.pdf
3. Transaction tracking.
Users are known not only by verifying their identity (who they are) but, above all, by analysing their transaction patterns (what they do). WE FINANCE CLUB LIMITED therefore relies on data analysis as a tool for risk assessment and suspicion detection. WE FINANCE CLUB LIMITED performs a number of compliance-related tasks such as data capture, filtering, record keeping, investigation management and reporting. System functionalities include:
– Checking users prior to each new investment against recognised “blacklists” (e.g. UK Treasury), aggregating transfers by multiple data points, placing users on watch and denial of service lists, opening cases for investigation where necessary, sending internal communications and completing regulatory reports where appropriate;
– Case and document management.
With respect to the AML/KYC policy, WE FINANCE CLUB LIMITED will monitor all transactions and reserves the right to:
– Ensure that transactions of a suspicious nature are reported to the competent authorities through the AML Compliance Officer;
– Request the User to provide additional information and documents in case of suspicious transactions;
– Suspend or terminate the User’s account when WE FINANCE CLUB LIMITED has reasonable suspicion that such User has engaged in illegal activity.
The above list is not exhaustive and the AML Compliance Officer will monitor Users’ transactions to define whether such transactions should be reported and treated as suspicious or should be treated as bona fide.
4. Risk Assessment.
WE FINANCE CLUB LIMITED, in line with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, WE FINANCE CLUB LIMITED can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the risks identified. This will enable resources to be allocated in the most efficient manner. The principle is that resources should be directed according to priorities so that the greatest risks receive the greatest attention.