POORDI TN 3-75 KESKLINNA LINNAOSA, TALLINN HARJU MAAKOND 10156

Know Your Customer (“KYC”) Policy

Ofinans OÜ” aims to provide the best and reliable service to its Clients in accordance with applicable laws. The purpose of the “KYC Policy” to raise the awareness and knowledge of employees about the Ofinans OÜ of customers, transactions and services, to reduce risk, to prevent money laundering and the financing of terrorism and to prevent the laundering of the proceeds of crime. It is to inform the customers that it has realised in accordance with the Ofinans OÜ applicable legislation, in particular the Law dated as 14th of January 2008 No. 4/2008 on the Prevention of Laundering Proceeds of Crime and the Law on the Prevention of the Financing of Terrorism.
Within the scope of this KYC Policy, customers who have a recognition policy in order to carry out Ofinans OÜ activities in accordance with the laws in force are the members of the platform accessed via www.ofinans.com (“SITE”) and benefit from the services provided on the Site and in return and real and legal persons who accept the issues. (“Customer”)
Ofinans OÜ has prepared this KYC Policy in accordance with international standards and applicable legislation.

1. Authentication
Pursuant to this KYC Policy, Ofinans OÜ applies with the following measure in accordance with the legislation in force and other internal policies.

• Customer identity verification

• Taking measures to identify the beneficiary as a result of Customer’s actions

• Obtaining satisfactory information about the purpose and nature of the transaction

• Monitoring the Customer and the transactions performed by the Customer during the customer relationship and comparing with the Customer profile

• Monitor high-risk Clients, transactions and other customers that need particular attention
Under the KYC Policy, the Customer’s identity shall be completed before aservice relationship is established between the Customer and that Ofinans OÜ or the Customer performs any transaction. During the establishment of the service relationship between the Customer and the Company, information shall be obtained on the purpose of the Customer to become a member of the Company’s Site and the actions it intends to perform on this Site. The customer authentication procedure will be executed in the following cases.

• When establishing any kind of service relationship, regardless of the monetary amount; also

• If the total amount of a single crypto currency transaction or multiple related transactions is equal to or more than 250,000 TL;

• If the total amount of a single crypto currency swap transaction or multiple linked transactions is equal to or more than 250,000 TL;

• Regardless of the monetary amount in cases requiring suspicious transaction notification under the current legislation

• Independently of the amount of money, if there is any doubt about the accuracy and adequacy of previously acquired credentials;

In the event that the Customer requesting a transaction on the Site carries out such transaction for the benefit of a third party; both the Customer requesting the transaction and the third party for the benefit of the transaction are authenticated. Customer declares that he is acting on his behalf; but where it is suspected that it acts for the benefit of a third party, that Ofinans OÜ shall take allmeasures to determine the identity of the actual beneficiary. Ofinans OÜ, in accordance with the legislation in the Site and in any environment; documents for twelwe years from the date of issuance and identification, and upon request, will be submitted to government agencies upon request.

2. Customers with No Service Relationship
Ofinans OÜ shall not establish any service relationship with the following Customer in accordance with the KYC Policy.

• Customers who want to open an account with anonymous or fake names

• Customers who refuse to provide the necessary information and documents

• Customers in lists published by international institutions (OFAC, EU, UN, HMT, etc.) on criminal proceeds and laundering of terrorism

• Where no authentication has been undertaken or sufficient information on the purpose of the service relationship is provided

• Customers who have a negative record of the financing of terrorism and related financial offences (fraud, counterfeiting, organised crime, etc.) in that Ofinans OÜ’s internal information system for money laundering,

• Illegal betting, gambling

3. Customers to be Taken Measures Before Establishing Service Relationship
As a result of Ofinans OÜ’s risk-based approach to Customers, Customers and transactions with the following characteristics are defined in the high risk category and will undergo a detailed review process.

• Political Person

• Non-profit organisations (associations, foundations, charities, etc.)

• People who are in countries or regions where crypto currency activities are prohibited and restricted.

• High amount of transactions

For the above-mentioned Customers and transactions, permission must be obtained from the Company’s senior manager before the service relationship is established or before the related transaction is performed. Before establishing a service relationship with the customers, information should be provided on the prevention of laundering proceeds of crime and financing of terrorism.
For detailed information you can contact us at [email protected]

Regards,

Ofinans OÜ

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