Anti-Money Laundering Policy

Disclaimers

GetEx (OÜ GetEx Technologies) does not open or maintain private banking accounts.

GetEx has reviewed accounts within the platform and it does not have, nor does it intend to open or maintain, correspondent accounts for foreign financial institutions.

It is the policy of the GetEx to prohibit and actively prevent Money Laundering and any activity that facilitates Money Laundering or Terrorist Financing or any other criminal activities by complying with all applicable requirements under the Money Laundering and Terrorist Financing Prevention Act (hereinafter – “MLTFPA”), International Sanctions Act and international standards and regulations.

Definitions

GetEx: a limited liability company OÜ GetEx Technologies, incorporated in Estonia under registered number 14596545 with registered address Nõmme tee 96, Kristiine linnaosa, Tallinn, Harju maakond, 13418.

User: an individual or a company, which has account with GetEx platform.

Money Laundering: 1) the concealment or disguise of the true nature, source, location, disposition, movement, right of ownership or other rights related to property derived from criminal activity or property obtained instead of such property; 2) the conversion, transfer, acquisition, possession or use of property derived from criminal activity or property obtained instead of such property for the purpose of concealing or disguising the illicit origin of the property or of assisting a person who is involved in criminal activity to evade the legal consequences of his or her action. Money laundering also means a situation whereby the criminal activity that generated the property to be laundered was carried out in the territory of another state.

Terrorist Financing: Financing or knowing supporting in another manner of commission of a criminal offence provided for in §§ 237, 2371 or 2372 of Estonian Penal Code, as well as a terrorist organization or a person, whose activities are directed at commission of a criminal offence provided in § 237 of Estonian Penal Code, and making available or accumulating of funds while knowing that these may be used in full or in part to commit a criminal offence provided for in §§ 237, 2371 or 2372 of Estonian Penal Code.

Beneficial owner: a natural person who, taking advantage of their influence, exercises control over a transaction, operation or another person and in whose interests or favor or on whose account a transaction or operation is performed.
Hereby GetEx shall establish written rules of procedure for taking the due diligence measures provided in MLTFPA, including assessment and management of the risk of money laundering and terrorist financing, collection and keeping of records and performance of the notification obligation and notification of the management, as well as internal control rules for checking adherence thereto.

Due Diligence Measures

    1. In economic or professional activities GetEx shall pay special attention to the activities of a User participating in a transaction or professional operation or of a person using a professional service or of a customer and to circumstances that refer to money laundering or terrorist financing or the connection of which with money laundering or terrorist financing is probable, including to complex, high-value and unusual transactions which do not have any reasonable economic purpose.
    2. GetEx shall take due diligence measures:
      • upon establishment of a business relationship;
      • upon carrying out or mediating on an occasional basis transactions the value of which exceeds 1 000 euros or an equal amount in another currency, regardless of whether the financial obligation is performed in the transaction in a single payment or in several linked payments;
      • upon suspicion of money laundering or terrorist financing, regardless of any derogations, exceptions or limits provided by law;
      • when the documents or data gathered earlier while identifying and verifying a person or while updating the respective data prove to be deficient or there is doubt about the veracity of the documents or data.
    3. To perform obligations imposed on GetEx by Estonian law, GetEx shall take the following due diligence measures in economic or professional activities:
      • identification of the User participating in the transaction on the basis of documents and data submitted by him or her and verification of the submitted information on the basis of information obtained from a reliable and independent source;
      • identification and verification of the representative of User and the right of representation;
      • identification of the beneficial owner, including gathering information about the ownership and control structure of the legal person, trust, civil law partnership or other contractual legal arrangement on the basis of information provided in pre-contractual negotiations or obtained from another reliable and independent source;
      • obtaining information on the purpose and nature of the business relationship and transaction;
      • constant monitoring of the business relationship, including monitoring transactions carried out during the business relationship, regular verification of data used for identification, updating relevant documents, data or information and, if necessary, identification of the source and origin of funds used in the transaction.
    4. GetEx shall take the due diligence measures provided in clause 3 (measures from 1 to 4) before establishment of any business relationship or carrying out any transaction.
    5. If a financial obligation is performed in a transaction in several linked payments and the total amount of these payments is unknown, the User must be identified and verified as soon as the exceeding of the amount of 1 000 euro becomes evident.
    6. GetEx shall take any and all due diligence measures specified in clause 3 of this Policy, but may choose the appropriate scope of taking of the due diligence measures based on the nature of the business relationship or transaction or the risk level of User participating in the transaction or professional operation, the User using a professional service or the customer.
    7. Upon taking the due diligence measures specified in clause 3, GetEx has the right to rely on information received by GetEx in a format that can be reproduced in writing from a credit institution registered in the Estonian commercial register or from the branch of a foreign credit institution or from a credit institution that has been registered or whose place of business is in acontracting state of the European Economic Area or a third country where requirements equal to those provided in this Act are in force.
    8. In their economic or professional activities GetEx shall pay special attention to business relations and transactions if the place of residence or seat of User participating in transaction or of User of the professional service or the seat of the provider of the payment service of the beneficiary is in a third country or in a territory where sufficient measures for preventing money laundering and terrorist financing have not been taken or if the country or territory is not engaged in international cooperation for prevention of money laundering and terrorist financing or if it is a low tax rate territory. The following countries and jurisdictions are considered to be the country or territory not engaged in international cooperation for prevention of money laundering and terrorist financing or a low tax rate territory:
      • Principality of Andorra
      • Anguilla (GBR)
      • Antigua and Barbuda
      • Aruba
      • Commonwealth of the Bahamas
      • Kingdom of Bahrein
      • Barbados
      • Belize
      • Bermuda Colony (GBR)
      • British Virgin Islands
      • State of Brunei Darussalam
      • Cook Islands
      • Republic of Costa Rica
      • Republic of Djibouti
      • Democratic People's Republic of Korea
      • Dominican Republic
      • Ethiopia
      • Republic of the Philippines
      • Gibraltar (GBR)
      • Grenada
      • Territory of Guam
      • Republic of Guatemala
      • Guernsey (GBR)
      • Iran
      • Iraq
      • Netherland Antilles (Curaçao and Sint Maarten)
      • Hong Kong
      • Jamaica
      • Cayman Islands (GBR)
      • State of Qatar
      • Republic of Kenya
      • State of Kuwait
      • Labuan
      • Republic of Liberia
      • Principality of Liechtenstein
      • Republic of Lebanon
      • Macau (Aomen)
      • Republic of the Maldives
      • Republic of the Marshall Islands
      • Republic of Mauritius
      • Principality of Monaco
      • Montserrat Colony (GBR)
      • Republic of Nauru
      • Republic of Niue
      • Sultanate of Oman
      • Republic of Panama
      • Commonwealth of Puerto Rico (USA)
      • French Polynesia
      • Saint Kitts and Nevis (Federation of Saint Christopher and Nevis)
      • Saint Lucia
      • Saint Vincent and the Grenadines
      • Republic of San Marino
      • Republic of Seychelles
      • Republic of Chile
      • Colony of Turk and Caicos Islands (GBR)
      • Eastern Republic of Uruguay
      • New Caledonia (FRA)
      • Republic of Vanuatu
      • Republic of Venezuela
      • United States Virgin Islands

Specifications for taking due diligence measures by GetEx

    1. Upon the first use of GetEx service by User, User participating in the transaction or using the service shall be identified.
    2. GetEx shall:
      • identify and verify each User upon establishment of a business relationship and carrying out a transaction while being present at the same place as the User, if the value of the transactions of the customer exceeds 1000 euros per calendar month or an equal amount in another currency;
      • upon mediation of a transaction between several customers, identify and verify each person participating in a transaction.
    3. Identification of Users can be done only by duly licensed provider of identification services, with whom GetEx shall conclude appropriate agreements.

Simplified due diligence measures

    1. GetEx may, in the event of a low risk of money laundering or terrorist financing, take the due diligence measures pursuant to a simplified procedure, determining the appropriate scope thereof pursuant to the nature of the business relationship or the risk level of the risk level of the transaction and User participating in the transaction or professional operation.
    2. Simplified due diligence measures shall not be taken if there is suspicion of money laundering or terrorist financing.
    3. GetEx shall gather enough information to identify whether a transaction performed in economic or professional activities or User participating in a transaction or professional operation complies with the conditions provided for in subsections of clause 15 of this Police.
    4. GetEx may take simplified due diligence measures if all of the following conditions have been fulfilled:
      • a written contract has been concluded with User for an indefinite period;
      • GetEx registers at least the data specified in clause 3 of this Policy with regard to a User.

Taking enhanced due diligence measures

    1. If the nature of a situation involves a high risk of money laundering or terrorist financing, GetEx shall take enhanced due diligence measures.
    2. GetEx shall take the enhanced due diligence measures specified in subsection 18 if:
      • User participating in a transaction performed in economic or professional activities or participating in a professional operation, or using a professional service or a customer has been identified and verified without being present at the same place as the person or customer;
      • upon identification or verification of User suspicion arises regarding the truthfulness of the data or authenticity of the documents submitted or regarding the identification of the beneficial owner or beneficial owners;
      • User participating in a transaction performed in economic or professional activities, or participating in a professional operation or using a professional service is a person specified in subsection 21 of this Policy.
    3. In the events specified in clauses 16 and 17 of this Policy, GetEx shall, in addition to the due diligence measures specified in clause 3 of this Policy, take at least one of the following enhanced due diligence measures:
      • identification and verification of User on the basis of additional documents, data or information, which originates from a reliable and independent source or from a credit institution or the branch of a credit institution registered in the Estonian commercial register or from a credit institution, which has been registered or has its place of business in a contracting state of the European Economic Area or in a country where requirements equal to MLFTPA are in force, and if in such credit institution the person has been identified while being present at the same place as User;
      • taking additional measures for the purpose of verifying the authenticity of documents and the data contained therein, among other things, demanding that they be notarized or officially authenticated or confirmation of the correctness of the data by the credit institution specified in clause above, which issued the document;
      • making the first payment relating to a transaction through an account opened in the name of a person or customer participating in the transaction in a credit institution which has its place of business in a contracting state of the European Economic Area or in a country where requirements equal to those provided for in MLFTPA are in force.
    4. GetEx is responsible for the proper taking of due diligence measures.

Politically exposed person

    1. A politically exposed person is a natural person who performs or has performed prominent public functions, their family members and close associates. A person who, by the date of entry into a transaction, has not performed any prominent public functions for at least a year, and the family members or close associates of such person are not considered politically exposed persons.
    2. A person performing prominent public functions is:
      1. a head of state, head of government, minister, deputy minister or assistant minister;
      2. a member of parliament;
      3. a justice of a supreme court, constitutional court or another court the judgments of which can be appealed against only in exceptional circumstances;
      4. a member of the supervisory board of a state audit institution or central bank;
      5. an ambassador, chargé d’affaires and senior officer of the Defence Forces;
      6. a member of a directing, supervisory or administrative body of a state company.
    3. The provisions of clauses 21 (1)-5)) include positions in the European Union and in other international organizations.
    4. A family member of a person performing prominent public functions is:
      1. his or her spouse;
      2. a partner equal to a spouse under the law of the person’s country of residence or a person who as of the date of carrying out the transaction had shared the household with the person for no less than a year;
      3. his or her children and their spouses or partners within the meaning of clause 2);
      4. his or her parent.
    5. A close associate of a person performing prominent public functions is:
      1. a natural person who has a close business relationship with a person performing prominent public functions or with whom a person performing prominent public functions is the joint beneficial owner of a legal person or contractual legal arrangement;
      2. a person who as a beneficial owner has full ownership of a legal person or contractual legal arrangement, which is known to have been founded for the benefit of the person performing prominent public functions.

Transactions with politically exposed persons of other Member States and third countries

    1. Upon establishment of a business relationship with or carrying out a transaction with or performance of a professional operation for or provision of a professional service to a politically exposed person of a contracting state of the European Economic Area or a third country or their family member or close associate, GetEx shall take the enhanced due diligence measures provided for in clause 18 of this Policy.
    2. In the event specified in clause 25, GetEx shall also implement the following requirements:
      • apply appropriate risk-based internal procedures for making a decision on establishment of a business relationship or entry into a transaction;
      • the management board of GetEx or a person or persons authorized by the management board shall decide on establishment of business relationships;
      • upon establishment of a business relationship and entry into a transaction, take appropriate measures for identification of the origin of the money or other property used;
      • continuously take the due diligence measures specified in clause 3 of this Policy.

Collection and Keeping of Records

Documents and data serving as basis for identification of natural persons

    1. GetEx shall identify a natural person and verify the User on the basis of a document specified in subsection 2 (2) of the Identity Documents Act or a valid travel document issued in a foreign country or a driving license complying with the conditions provided in subsection 4 (1) of the Identity Documents Act. In addition to an identity document, the representative of User participating in a transaction shall submit a document in the required format, certifying the right of representation.
    2. A copy shall be made of the page of an identity document submitted for identification, which contains the personal data and a photograph. In addition, upon identification and verification of the User’s representative, GetEx shall register the following personal data:
      • the name and the representative’s name;
      • the personal identification code or, upon absence of a personal identification code, the date and place of birth;
      • the name and number of the document used upon identification and verification of persons, and its date of issue and the name of the agency which issued the document;
      • the name of the document used upon identification and verification of the right of representation, and its date of issue and the name of the issuer.
    3. Based on the information received from the person specified in clause 27, GetEx shall register the address of the place of residence and the profession or area of activity of the person.
    4. User participating in a transaction performed in economic or professional activities, or participating in a professional operation or using a professional service shall, at the GetEx’s request, submit documents and provide relevant information required for taking the due diligence measures specified in clause 3 of this Policy.
    5. A representative of a legal person of a foreign country shall, at the GetEx’s request, submit a document certifying his or her powers, which has been notarized or authenticated pursuant to an equal procedure and legalized or authenticated by a certificate substituting for legalization (apostille), unless otherwise prescribed by an international agreement.
    6. User participating in a transaction or professional operation performed in economic or professional activities, at the request of GetEx, shall certify the correctness of the submitted information and documents by signature.
    7. GetEx shall identify a legal person and its passive legal capacity and verify the information obtained. Legal persons registered in Estonia and branches of foreign companies registered in Estonia shall be identified on the basis of an extract of a registry card of the relevant register and foreign legal persons shall be identified on the basis of an extract of the relevant register or a transcript of the registration certificate or an equal document, which has been issued by a competent authority or body not earlier than six months before submission thereof.
    8. The document submitted for identification shall set out at least:
      1. the business name or name, seat and address of the legal person;
      2. the registry code or registration number;
      3. the date of issuance of the document and the name of the agency which issued the document.
    9. On the basis of the documents specified in clauses 33 or 34, if the aforementioned documents do not contain the respective data, on the basis of the information received from the representative of the legal person participating in the transaction, GetEx shall register the following data:
      1. the names of the director or the members of the management board or a body substituting for it and their authorization in representing the legal person;
      2. the area of activity of the legal person;
      3. telecommunications numbers;
      4. the data of the beneficial owners of the legal person.
    10. If GetEx has information that a politically exposed person of another contracting state of the European Economic Area or a third country may be related to User participating in a transaction carried out in economic or professional activities, the circumstances specified in clause 35 shall be registered on the basis of the information received from the representative of the legal person in addition to the data specified in 35.
    11. An extract of the registry card does not have to be submitted if the obligated person has access to the data of the commercial register and the register of non-profit associations and foundations via a computer network.
    12. If the document or data specified in clauses 33 and 35 cannot be received, documents certified or authenticated by a notary or authenticated officially shall be used for verification of the identity of a person.
    13. The documents and data received from the User GetEx shall transfer to the duly licensed provider of Identification services, with whom GetEx has established business relationship, for the purposes of confirmation of correctness and legality of obtained documents.
    14. Upon identification and verification of User, GetEx shall register the date or period of time of entry into a transaction and a description of the content of the transaction.
    15. GetEx shall keep the electronic copies of the documents specified clauses 33-35, which serve as the basis for identification and verification of User, and of the documents serving as the basis for establishment of a business relationship, for no less than five years after termination of the business relationship.
    16. GetEx shall keep on any data medium the documents prepared with regard to a transaction and the documents and data serving as the basis for the notification obligations in event of suspicion of money laundering or terrorist financing for no less than five years after carrying out the transaction or performance of the notification obligation.
    17. GetEx shall keep the documents and data specified in clauses 33-35 in a manner, which allows for a full and immediate reply to enquiries received from the Financial Intelligence Unit or, pursuant to legislation, from other investigative bodies or a court.
    18. If GetEx makes, for the purposes of identifying a person, a query to a database that is part of the state information system the use of which is obligatory for GetEx under the legislation in force, the obligation provided for in clauses 33 and 35 of this Policy shall be deemed complied with if the information about making the electronic query to the corresponding register can be reproduced over a period of five years after the end of the business relationship.
    19. GetEx, being Estonian company, is obliged meet all standards and requirements of GDPR when processing User’s data.

Management of Risks Relating to Money Laundering and Terrorist Financing

Refusal from transaction and termination of business relationship

    1. GetEx is prohibited to establish a business relationship or to carry out a transaction if User participating in the transaction or professional operation, or using professional services, regardless of the respective request, does not submit the documents or relevant information required for complying with the due diligence measures specified in clause 3 of this Policy or if on the basis of the documents submitted GetEx has reasonable doubt that the situation may constitute money laundering or terrorist financing.
    2. GetEx has the right to refuse to carry out a transaction if User participating in a transaction or professional operation, or using a professional service, regardless of the respective request, does not submit the documents or relevant information required for identification of the circumstances specified in clause 3 of this Policy or data certifying the legal origin of the property constituting the object of the transaction or if the data and documents submitted make the obligated person suspect money laundering or terrorist financing.
    3. If User participating in a transaction carried out in economic or professional activities , regardless of the respective request, does not submit documents and relevant information required for performance of the obligation specified in clause 3 of this Policy, it shall be deemed a fundamental breach of contract and the GetEx shall be required to, without following the term of advance notification, extraordinarily cancel the contract concluded for an indefinite period, which serves as the basis for the business relationship.
    4. Any agreement violating the prohibition provided for in clause 46 shall be null and void.
    5. GetEx shall register and record:
      • information about the circumstances of refusal to establish a business relationship or carry out a transaction;
      • the circumstances of giving up the establishment of a business relationship or carrying out a transaction on the initiative of User, provided that the giving up is related to the taking of due diligence measures by GetEx;
      • the circumstances of termination of a business relationship provided for in clause 48;
      • the information serving as the basis for the notification obligation arising in event of suspicion of Money Laundering or Terrorist financing.

Outsourcing of activities relating to economic or professional activities of obligated persons

    1. GetEx can outsource an activity to a third party for the purpose of better performance of the obligations related to its economic or professional activities, it shall be deemed that the third party knows of any and all requirements arising from MLTFPA. In case of outsourcing its activities, GetEx is liable for infringement of the requirements.
    2. The outsourcing of an activity is permitted only if:
      • it does not harm the justified interests of GetEx or User;
      • it does not impede the activities of GetEx or performance of its obligations provided in MLTFPA;
      • it does not impede exercising state supervision over GetEx;
      • the third party to whom the activities are outsourced has the required knowledge and skills and it is able to fulfil the requirements provided for in MLTFPA;
      • GetEx has the right and opportunity to check performance of the requirements provided in MLTFPA by the third party;
      • it is ensured that the documents and records collected for fulfilment of the requirements arising from MLTFPA are kept pursuant to the procedure provided for in MLTFPA and legislation adopted on the basis of MLTFPA.
    3. GetEx shall notify the competent supervisory authority about outsourcing its activities.

Internal security measures

    1. The management of GetEx shall ensure the provision of regular training in the performance of duties arising from MLTFPA for employees whose duties include establishment of business relationships or carrying out transactions. The training shall, among other things, give information about the modern methods of money laundering and terrorist financing and the related risks.
    2. GetEx may appoint a compliance officer for performance of the duties related to prevention of money laundering and terrorist financing. If a compliance officer has not been appointed, the duties of a compliance officer shall be performed by the management of GetEx.
    3. An employee or a structural unit may perform the functions of the compliance officer. If a structural unit performs the duties of the compliance officer, the head of the respective structural unit shall be responsible for performance of the given duties. The competent supervisory authority shall be notified of appointment of the compliance officer.
    4. The functions of the compliance officer are:
      • organization of collecting and analysis of information referring to unusual transactions or transactions suspected of money laundering or terrorist financing in the activities of the obligated person;
      • notification of the Financial Intelligence Unit in the event of suspicion of money laundering or terrorist financing;
      • periodic submission of written statements on implementation of the rules of procedure to the management of GetEx;
      • performance of other obligations, which are related to the fulfilment of the requirements of MLTFPA by GetEx.
    5. The compliance officer has the right to:
      • make proposals to the management of GetEx for amending or modifying the rules of procedure containing requirements for prevention of money laundering and terrorist financing, or for organizing training specified in clause 54;
      • demand that the structural units of GetEx eliminate within a reasonable term the deficiencies detected in the implementation of the requirements for prevention of money laundering and terrorist financing.

Conduct in event of suspicion of Money Laundering or Terrorist Financing

  1. If, upon performance of economic or professional activities or professional operations or provision of professional services, GetEx identifies an activity or circumstances which might be an indication of money laundering or terrorist financing or an attempt thereof or in the event of which GetEx has reason to suspect or knows that it is money laundering or terrorist financing, GetEx shall immediately, but not later than within two working days from identifying the act or circumstances or from the rise of the suspicion, notify the Financial Intelligence Unit thereof.
  2. GetEx shall immediately, but not later than within two working days of executing the transaction, notify the Financial Intelligence Unit of any transaction where the financial obligation exceeding 32 000 euros or an equal amount in another currency is performed in cash, regardless of whether the transaction is carried out in a single payment or in several linked payments.
  3. GetEx has the right to postpone the transaction or professional operation in the event specified in clause 59. If the postponement of a transaction may cause considerable harm, the transaction has to be carried out or if it may impede catching User who possibly committed money laundering or terrorist financing, the transaction or professional operation shall be carried out and the Financial Intelligence Unit shall be notified thereafter.
  4. The information shall be transmitted to the Financial Intelligence Unit of Estonia.
  5. A notification shall be communicated orally, in writing or in a format which can be reproduced in writing. If a notification was communicated orally, it shall be repeated the next working day in writing or in a format which can be reproduced in writing.
  6. The data used for identifying and verifying User or, where necessary, copies of relevant documents shall be appended to a notification.
  7. GetEx, and a structural unit, a member of a directing body and an employee of GetEx who is a legal person is prohibited to notify a person, the beneficial owner or representative of the person about a notification given to the Financial Intelligence Unit about the person and about precepts made by the Financial Intelligence Unit or initiation of criminal proceedings. After a precept made by the Financial Intelligence Unit has been complied with, GetEx may notify a person that the Financial Intelligence Unit has restricted the use of the person’s account or that other restrictions have been imposed.
  8. The provisions of clause 59 also apply in the event of provision of information to third parties, unless otherwise provided in MLTFPA.
  9. GetEx may give information to a third party if:
    1. the third party belongs to the same consolidation group as GetEx and the undertaking is located in a contracting state of the European Economic Area or third country where requirements equal to those provided in MLTFPA are in force, state supervision is exercised over fulfilment thereof and requirements equal to those in force in Estonia are applied for the purpose of keeping professional secrets and protecting personal data;
    2. the third party acts in the same legal person or structure, which has joint owners and a joint management or internal control system, as GetEx who pursues the profession of a notary, attorney or auditor;
    3. the information specified in clause 59 concerns the same person and the same transaction which is related to several obligated persons under MLTFPA and the information is given by a credit institution, financial institution, notary, attorney or auditor to a person operating in the same branch of the economy or profession and located in a contracting state of the European Economic Area or third country where requirements equal to those provided in MLTFPA are in force, state supervision is exercised over fulfilment thereof and requirements equal to those in force in Estonia are applied for the purpose of keeping professional secrets and protecting personal data.Information exchanged pursuant to subsection (3) maybe used solely for the purpose of prevention of money laundering and terrorist financing.
  10. GetEx, its employee, representative or a person who acted in its name shall not, upon performance of the obligations arising from MLTFPA, be liable for damage arising from failure to carry out a transaction or failure to carry out a transaction by the due date if the damage was caused to User participating in the transaction made in economic or professional activities in connection with notification of the Financial Intelligence Unit of the suspicion of money laundering or terrorist financing in good faith, or for damage caused to User participating in a transaction carried out in economic or professional activities in connection with cancellation of a contract concluded for an indefinite period on the basis provided in clause 48 of this Policy.
  11. The performance in good faith of the notification obligation arising from clause 59 and communication of relevant data by GetEx is not deemed infringement of the confidentiality requirement provided by law or contract and no liability provided by legislation or contract is imputed with regard to the person who performed the notification obligation for disclosure of the information. An agreement derogating from this provision is void.

Important Information for Users

GetEx will provide notice to Users that it is requesting information from them to verify their identities, as required by MLTFPA. GetEx will use the following method to provide notice to Users: the following text with notification will be the first the client will see after the login in to his personal account for the first time:
"Important Information About Procedures for Opening a New Account"
To help the international fight against the funding of terrorism and money laundering activities, law requires us to obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name, citizenship, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.
"Thank you for your understanding. Trade with GetEx!"
GetEx also reserves the following Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

Users – Insufficient or Suspicious Information
  • Provides unusual or suspicious identification documents that cannot be readily verified.
  • Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect.
  • Background is questionable or differs from expectations based on information provided.
  • Customer with no discernable reason for using the firm’s service.
Efforts to Avoid Reporting and Recordkeeping
  • Tries to persuade an employee not to file required reports or not to maintain required records.
  • Unusual concern with the firm’s compliance with government reporting requirements and firm’s AML policies.
Certain Digital Assets Transfer Activities
  • Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent business reason.
  • Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.
Other suspicious Activities
  • Client has opened multiple accounts with the same beneficial owners or controlling parties for no apparent business reason.
  • Opens and closes accounts with one legal entity then reopens a new account shortly thereafter with the same legal entity, each time with new ownership information.
  • Maintains multiple accounts, or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose.
  • Appears to be acting as an agent for an undisclosed principal, but is reluctant to provide information.
  • Law enforcement subpoenas.

If sufficient number of Rad flags is raised, GetEx will determine whether or not and how to further investigate the matter through the voting procedure.

An independent third party, which will be determined until the end of first year of the AML program, will perform the testing of GetEx AML program at least annually. GetEx will evaluate the qualifications of the independent third party to ensure they have a working knowledge of applicable MLTFPA requirements and its implementing regulations.

After the independent testing is completed, GetEx will report its findings to the general public. GetEx will immediately address each of the resulting recommendations and keep a record of how each noted deficiency was resolved.