Definitions
Account: means an account registered by the User on the Julian Trade OU website or other Internet services, owned and operated by Julian Trade OU.
Services: mean all and any service provided by Julian Trade OU.Transaction: means (i) transfer of Cryptocurrencies or Fiat currencies by the User to his/her Account ("Deposit Transaction"); (ii) withdrawal of Cryptocurrencies or Fiat currencies from his/her Account ("Withdrawal Transaction").
User: means a person or an entity, who uses the Services, agreed to the Terms of Use and is a holder of an Account.Withdrawal: means a Transaction involving a transfer of Funds from the User's Account to his/her bank account or to account opened in any other financial institution.
Where the context so admits words denoting the singular shall include the plural and vice versa.
Introduction
Julian Trade OU Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML/KYC Policy") is designated to prevent and mitigate possible risks of being involved in any kind of illegal activity.
Both international and local regulations require Julian Trade OU 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 Users.
AML/KYC Policy covers the following matters:
Verification procedures
Compliance Officer
Monitoring Transactions
Risk Assessment
1. Verification procedures One of the international standards for preventing illegal activity is customer due diligence ("CDD"). According to CDD and "Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines for Banks, Financial Institutions, Credit Unions and Money Transfer Services Providers" by Central Bank of Belize (the Guidelines), Julian Trade OU establishes its own verification procedures.
Identification and verification procedures (also known as 'Know Your Customer' or ' KYC') are required for all Transactions, which involve Fiat currency. On its sole discretion Julian Trade OU may apply mentioned KYC procedures to Users, who make Transactions exclusively in Cryptocurrency. If the User refuses to provide required documents and information, Julian Trade OU reserves the right to immediately terminate Services provision to the User.
Identity verification
According to the Section IV of the Guidelines, Julian Trade OU's identity verification procedure requires the User to provide Julian Trade OU with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Julian Trade OU reserves the right to collect User's identification information for the AML/KYC Policy purposes.
Julian Trade OU will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Julian Trade OU reserves the right to investigate certain Users who have been determined to be risky or suspicious.
User's identification information will be collected, stored, shared and protected strictly in accordance with the Julian Trade OU privacy policy and related regulations.
Once the User's identity has been verified, Julian Trade OU is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
Card verification
The Users who are intended to use payment cards in connection with the Julian Trade OU Services have to use third-party credit card payment providers, offered by Julian Trade OU. In such case Julian Trade OU is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
2. Compliance Officer The Compliance Officer is the person, duly authorized by Julian Trade OU, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer's responsibility to supervise all aspects of Julian Trade OU anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users' 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.
3. Monitoring Transactions The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Julian Trade OU relies on data analysis as a risk-assessment and suspicion detection tool. Julian Trade OU performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.
System functionalities include: Daily check of Users against recognized "black-lists" (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable.
Case and document management. With regard to the AML/KYC Policy, Julian Trade OU will monitor all transactions and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User's Account when Julian Trade OU has reasonable suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users' transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Risk Assessment Julian Trade OU, in line with the international and local requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Julian Trade OU 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.
5. Obligations to the user of Julian Trade OU services By using Julian Trade OU services, I confirm that me or *close family members or **close associates are not politically exposed natural persons. Otherwise I will inform Julian Trade OU about this situation by written notice to e-mail JulianTradeOU@gmail.com.
*Close family members mean the spouse, the person with whom partnership has been registered (hereinafter referred to as cohabitant), the parents, brothers, sisters, grandparents, grandchildren, children and children's spouses, children's cohabitants.
**Close associate means a natural person who, together with the person who is or has been participating in the same legal person or maintains other business relations.
By using Julian Trade OU services I hereby confirm that I am the actual owner (beneficiary) of funds.
By using Julian Trade OU services I hereby confirm that I undertake all operations on my behalf and I am not authorized by any other person to undertake operations on his/her/its behalf. Otherwise I will inform Julian Trade OU about this situation by written notice to e-mail JulianTradeOU@gmail.com.