UTELIMITED

AML and KYC Policy

ANTI-MONEY LAUNDERING (AML) POLICY
KNOW YOUR CUSTOMER (KYC) POLICY
Russian ver.
1. The AML and KYC Policy applies to ute.limited and its partners and Customers (hereinafter referred to as the "Company") and is aimed at preventing and actively preventing money laundering and any other activities that facilitate money laundering or the financing of terrorist or criminal activities. The Company requires its managers, employees and branches to follow the principles of this Policy in order to prevent the use of its services for money laundering purposes.

2. Within the framework of this Policy, as a rule, there are actions aimed at concealing or distorting the true origin of funds obtained by criminal means in order to launder illegal income.

3. Money laundering usually takes place in three stages. Initially, at the stage of "placement", cash enters the financial system, where money received as a result of criminal acts is converted into monetary instruments such as money transfers, traveler's checks or placed in accounts with financial institutions. At the "stratification" stage, funds are transferred or moved to other accounts or other financial institutions to further separate the money from its criminal origin. At the stage of "integration", funds are returned to the economy and used to purchase property, finance business or criminal activities. Funds received from criminal activities may not be used in the financing of terrorism; most likely, this is an attempt to conceal the origin or intended use of funds that will later be used for criminal purposes.

4. The Client assumes obligations: comply with legal norms, including international ones, aimed at combating illegal trade, financial fraud, laundering and legalization of illegally obtained funds; to exclude direct or indirect complicity in illegal financial activities and any other illegal transactions using the Site.

5. The Client guarantees the legal origin, legal possession and right to use the funds transferred to the Company's Accounts. In case of suspicious or fraudulent cash deposits, including the use of stolen credit cards and/or any other fraudulent activity (including any refunds or cancellations of payments), the Company reserves the right to block your account and cancel any payments made, as well as investigate the nature of questionable transactions on the Client's Account, as a result of which suspend such transactions until finding out the causes of their occurrence and the end of the investigation.

6. During the investigation, the Company reserves the right to request from the Client copies of the identity card and bank cards used to replenish the Account, payment documents, as well as other documents confirming the legal possession and legal origin of funds. The Client is prohibited from using the services and/or the software for any illegal or fraudulent activity, or for any illegal or fraudulent transaction (including money laundering) in accordance with the laws of the Client's country of jurisdiction. The Company's refusal to conduct suspicious transactions is not a reason for the occurrence of civil liability of the Company for non-fulfillment of obligations towards the Client.

7. Each division of the Company must be guided by the AML and KYC policy, drawn up in accordance with the requirements of local legislation.

8. All personal and official documentation will be stored for a minimum period of time established by local legislation.

9. All new employees are required to undergo AML and KYC training. Existing employees are trained annually. Participation in additional training programs is mandatory for all employees related to AML and KYC.

10. The Company has the right to require the Client to confirm his registration information specified when opening a trading account at its discretion and at any time. In order to verify the data, the Company may request the Client to provide notarized copies of: passport, driver's license or national identity card to confirm identity; bank statement or utility bill to confirm the address of residence. In special cases, the Company may ask the Client to provide a photo of the Client holding an ID card next to his face. Detailed requirements for customer identification are listed in the "AML Policy" section on the Company's official website.

11. The verification procedure of the Client's identification data is not mandatory, provided that the client has not received such a request from the company. The Client may voluntarily send a copy of his passport or other document confirming his identity to the Company's customer relations department to ensure verification of the specified personal data. The client should take into account that when making deposits/withdrawals via bank transfer, it is necessary to provide documents for full verification of the name and address in connection with the specifics of the implementation and processing of banking transactions.

12. If any of the Client's registration data (full name, address or phone number) has been changed, the Client is obliged to immediately make appropriate changes to the data specified in the personal profile in the Company or notify the Company's customer service department of such changes.

12.1. In order to change the phone number specified during registration of the client profile, we require you to provide a document confirming the ownership of the new number (an agreement with a mobile provider) and a photo of the identity document that the client holds next to his face. The client's personal data in both documents must match.

13. The Client is responsible for the authenticity of the documents (their copies) and recognizes the Company's right to contact the relevant authorities of the country of the document issuer to confirm their authenticity.

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