AML & KYC Policy
In line with the safety of our users and the legal requirements of Canada, the European Union, the United States of America, and other jurisdictions, PIGGY PAY INC. has implemented and adopted KYC (Know Your Customer) and AML/CTF (Anti-Money Laundering and Counter- Terrorism Financing) policies, as mandated by FINTRAC (Financial Transactions Reports Analysis Centre of Canada).
The purpose of these policies is to effectively combat money laundering and terrorist financing (AML/CTF). Through proper identification of the actual users of our platform and close monitoring of their transactions, we aim to identify and prevent transactions that not only involve the purchase or sale of cryptocurrency but are primarily intended to disguise the criminal origin of funds, finance illegal activities, or engage in other unlawful conduct.
Specific provisions of our policies are confidential and intended for internal use only, in order to prevent evasion by dishonest or fraudulent users. However, we would like to introduce some general rules and guidelines that directly concern you and impact the services we provide.
User’s identification
In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to do transactions on our platform. This is the reason why we collect ID scans, which authenticity is verified with special software of professional external providers.
We require sending “selfie” or your recording with ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made with the use of special software of professional external providers or, in case of doubts, done manually by our customer support services.
In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arose.
If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are the authentic we won’t be able to let you execute any transactions.
Questionnaire "Know Your Customer»
Why do we ask for personal information?
Every client expects their financial institution to provide high-quality services and ensure the safety of their funds. To meet these expectations, financial institutions worldwide adhere to the principle of "Know Your Customer," and we are no exception.
In line with this principle, we periodically ask our clients questions about their financial activities and request regular updates of their personal information in the system. This process does not imply any suspicion of illegal activity and applies to all clients without exception. Collecting this information helps prevent financial fraud and identity theft, thereby safeguarding your funds and protecting your interests.
After registering on the site, you can receive a letter with a KYC Questionnaire to your registered email. You need to carefully answer the questions and send us the questionnaire by return email to [email protected].
It is important to understand that each form is completed individually, and the answers will vary depending on your field of activity, income, and other factors.
Here are some guidelines for completing the KYC form:
1. Sources of Funds
Select where your funds come from. Multiple answers may be selected. For example, if your primary income source is your salary, but you also earn from individual activities, select both options. If you selected options like individual activity or other sources, please specify the type of activity or other sources from which you receive funds.
2. Planned Monthly Turnover
Indicate your expected monthly turnover. For example, if your monthly income is around 800 EUR with no other income sources, select the “up to 1,000 EUR” option.
3. Involvement in Political Activities
Specify if your work is related to politics, for example, if you work in the parliament or are a member of a political party. Select "yes" if you have engaged in such activities within the last year.
4. Close Associates
Do any of your close associates engage in political activities or hold significant positions in international or national institutions? Select "yes" if this occurred within the last 12 months, for example, eight months ago.
5. Ultimate Beneficiary
The ultimate beneficiary is the account holder and the person who owns the funds in the account. Please note that you can open an account for personal use only.
How often do we ask for data?
• During registration;
• About once a year to update existing data;
• In case of unusual actions for the client, making a large payment or repeating small payment transactions. In such cases, we may ask additional questions about the purpose of the payment, the source of funds, etc.
What happens if I don't provide the data?
In some cases, clients who fail to provide the required data in a timely manner will not be able to use certain financial services.
The faster and more accurately you answer all our questions and provide the necessary documents and other information, the faster we can complete your transfer, remove restrictions on account use, or simply give you the right to use all Piggy Pay services.
Which institutions will have access to my data?
We store personal customer data responsibly and use it only for security purposes.
However, we cooperate with law enforcement agencies that have the right to contact payment service providers to obtain information about the customer's financial activity.
Information
We may ask customers to provide various information - from contact details to details of specific payment transactions. This information is carefully guarded and is not used for marketing or other non-security purposes. Security of funds. Preventive measures of this kind are taken to protect the funds and interests of not only our customers, but also other people from financial fraud.
Laws
Obtaining information about the client's activities is regulated by laws that all financial institutions follow. Constant monitoring and updating of customer information is an important component in the fight against money laundering and terrorist financing.
User’s identification – Companies
For all legal entities (companies), the AML/KYC procedure is stricter and depends on the company's structure, jurisdiction, and the nature of its activities. The initial step is to establish the company's ownership structure, identify the individuals authorized to represent it, verify its registered address, and understand its line of business.
This process includes verifying ownership chains to identify any ultimate beneficial owners, which may require assessing shareholders, partners, or holding structures if applicable. The purpose is to ensure compliance with regulatory requirements and prevent the company from being used for money laundering or other illicit activities.
Since official documentation standards vary by country, verification of legal entities is often conducted manually to meet the requirements of each specific jurisdiction. This process may include the collection and review of the following documents:
• Certificate of Incorporation to confirm the company’s legal existence.
• Founding documents (e.g., Articles of Association or Incorporation Agreement) outlining the company’s structure and activities.
• Identification documents for directors and authorized representatives, including proof of identity and address for key individuals.
• Shareholder agreements or partnership contracts to identify and verify all significant stakeholders and, where applicable, beneficial owners.
• Proof of registered address (e.g., recent utility bills or lease agreements).
• Financial statements or bank references to confirm the company's financial stability and business legitimacy.
Enhanced due diligence (EDD) may also be required if the company operates in a high-risk jurisdiction, belongs to a high-risk industry, or if any red flags are identified. This may involve further investigation, such as open-source research, checks against sanctions lists, and additional documentation requests.
Given the complexity and need for accuracy, manual verification can be time-consuming but ensures a reliable compliance process that safeguards both the financial institution and our clients.
Transactions’ monitoring and supervision
Using our proprietary software we also analyse all transactions that take place on our platform looking for suspicious and unusual behaviours. Such selected transactions are analysed by our AML specialists and evaluated if they do not provide significant AML / CTF risks or if they needed to be ceased and clarified with the User.
Additional verification
When your trade volume increases, our AML/CTF verification obligations also intensify. This applies when your transactions are flagged as suspicious or unusual, or if our assessment determines that you pose a significant AML/CTF risk. In such cases, we may require additional documentation to verify your actual place of residence, education, occupation, and the source of the funds you are using on our platform. Unfortunately, if our AML specialists determine that the information you provide does not sufficiently address our concerns, we will be obligated to terminate our relationship with you and may report your transactions to the relevant authorities.
Basic AML/CTF Rules
AML/CFT Basic Rules
Our operating rules include, but are not limited to, the following:
• piggypay.io gets to know each client by following the Know Your Client rule;
• piggypay.io does not accept cash deposits or cash withdrawals under any circumstances;
• piggypay.io does not allow any exceptions regarding the documentation required from users;
• piggypay.io reserves the right to refuse to process a user's transaction at any time if there is a suspected AML/CFT risk;
• In accordance with international law, we do not inform our clients if we report suspicious behavior to the relevant government authorities;
Sanctioned countries
In accordance with our policies we do not sell goods and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission) impose high AML / CTF high risk.
Currently, these countries are:
Afghanistan, American Samoa, Angola, Bahamas, Botswana, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states), Russian Federation, Belarus.
Tiers of KYC verification
Each client who registers on https://piggypay.io is obliged to pass KYC-AML verification with our AML provider https://sumsub.com through the integrated link in the https://piggypay.io personal account. When your trade volume rise AML / CTF risk increases as well. That is why we have to introduce proper safety and verification procedures. As a result, we introduced three Tier verification system, based on the general rule that the more money you buy or sell the more information about you and your funds we need to exclude AML / CTF risks (as we are required by law).
You should remember that this model is a result of the work and experience of our AML team and can be changed as the legal requirements of countries changes as well as a result of gaining new knowledge and experience. In particular transition, limits may change due to periodical audits and verification of efficiency of our procedures. We will keep you updated if any changes would influence your situation.
10.09.2024