AML/ KYC Policy

VERNA PAYMENTS LIMITED, a company incorporated in Canada. As a regulated Company, we are required to comply with the applicable anti-money laundering and countering financing of terrorism legislations in Canada, in order to prevent any exposures to money laundering and terrorist financing and also ensuring compliance with the international standards.

Customer Due Diligence

In our efforts to counter money laundering and terrorist financing and be in compliance with the applicable Legislations, we apply the following due diligence measures:

1. identification of customers or persons participating in an occasional transaction and verification of the submitted information;
2. identification and verification of a representative of a customer or person participating in an occasional transaction and their right of representation;
3. identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer or of the person participating in an occasional transaction;
4. understanding of business relationships, an occasional transaction or operation and, where relevant, gathering information thereon;
5. gathering information on whether a person is a politically exposed person, their family member or a person known to be close associate;
6. monitoring of a business relationship.

KYC Procedures

In compliance with the applicable Legislation, we will ask for certain minimum identification information from each customer which opens an account with the Company.

This minimum information may include:

1. Full name;
2. Date of birth;
3. Country of birth;
4. Gender;
5. Citizenship;
6. Email address;
7. Phone number;
8. Identity document information;
9. Residential address.

The Company will request from customers relevant documentation to verify the above information.

Upon establishing a relationship with a legal entity, the following information shall be collected and verified:

1. Full legal and trade name;
2. Company number
3. Legal form
4. Legal status
5. Legal address
6. Controlling persons and their legal capacity
7. Authorised representatives (other than controlling persons) and their legal capacity
8. Shareholders and ultimate beneficial owners (UBO);
9. Purpose of account
10. Expected activity on the platform
11. Source of entity’s funds;
12. Other information which may be required for conducting identification and verification of the legal entity.

The Company applies enhanced due diligence measures for clients considered to be high risk. Therefore, we might request from you additional information and/or documentation.

Restricted Business and jurisdictions

To minimize any risk of money laundering and terrorist financing our Company does not provide services to clients that their activities are associated with any high risk or banned activities. For example:

• Clients who are involved in adult entertainment;
• Clients dealing with weapons;
• Companies with bearer shares form;
• Client accounts in the name of a third person;
• Shell banks;

Further, we are not accepting clients from the following jurisdictions:

• Afghanistan

• American Samoa

• Angola

• Anguilla

• Bahamas

• Barbados

• Belarus

• Belize

• Benin

• Bonaire, Saint Eustatius and Saba

• Botswana

• British Indian Ocean Territory

• Burkina Faso

• Burundi

• Cambodia

• Cameroon

• Central African Rep

• Chad

• Christmas Island

• Cocos (Keeling) Islands

• Colombia

• Congo (Brazzaville)

• Congo, the Democratic Republic

• Cook Islands

• Cuba

• Djibouti

• Dominica

• Egypt

• El Salvador

• Equatorial Guinea

• Eritrea

• Ethiopia

• Fiji

• Gaza Strip (Palestinian Territory)

• Ghana

• Guam

• Guinea

• Guinea Bissau

• Haiti

• Iran, Islamic Republic of

• Iraq

• Jamaica

• Kiribati

• Lebanon

• Liberia

• Libya

• Mali

• Myanmar

• New Caledonia

• Nicaragua

• Niger

• Nigeria

• Norfolk Island

• North Korea

• North Mariana Islands

• Pakistan

• Palau

• Panama

• Russian Federation

• Rwanda

• Saint Barthelemy

• Saint Martin (French part)

• Saint Pierre and Miquelon

• Samoa

• Seychelles

• Sierra Leone

• Somalia

• South Sudan

• St Maarten

• Sudan

• Syria

• Tajikistan

• Tokelau

• Trinidad & Tobago

• Turkmenistan

• Uganda

• United States Virgin Islands

• Vanuatu

• Venezuela

• West Bank (Palestinian Territory)

• Western Sahara

• Yemen

• Zambia

• Zimbabwe

• Western Sahara

• Yemen

• Zambia

• Zimbabwe

We also reserve the right to refuse any client without giving reason.

Sanctions Screening

The Company performs through market leading databases sanction screening of all of its potential customers on the same matching rules, as for PEP screening.

The Company will perform screening, at minimum, against the following sanctions lists:

• Politically exposed persons (including relatives & close associates) (market leading global PEP database aligned to regulatory guidance since 2002 and 3rd, 4th and 5th EU directives).
• UN Sanctions;
• EU Sanctions;
• Unique Sanctions Ownership Research (entities owned or controlled by OFAC or EU sanctioned individuals) not available through other providers
• Special Interest Persons – people indicted, charged or arrested for specific types of criminal conduct

All matches (true hits) will be escalated to a Compliance Officer for further action and processing.

Monitoring and Ongoing Customer Due Diligence

We will continuously monitoring your transactions and overall behavior while you are using our services. We also put the best efforts to ensure that your information is up to date, so we may request to occasionally update your personal data during the course of our business relationship. We also may take an appropriate action such as suspending your account or transaction for further investigation if we deem it necessary in order to protect you and the Company from any potential illegal activity.

In an effort to prevent money laundering and other illegal activity, we do not permit any cash transactions, regardless of their stated purpose or any fiat transaction, i.e. transferring any fiat amounts from one client to another client.

We have the right to cancel or deny a transaction at any point if there are suspicions regarding its legality.

Data Retention

The Company will store your personal data collected for the purpose of establishing business relationship with you for minimum period of 5 years from the date of terminating your business relationship with the Company.

You may find additional information on collection and storage of your personal data in the Company’s Privacy Policy.

By applying for an account with us you agree to promptly provide us with all the information that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering.