Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last Revised: 5 April 2018

Thank you for visiting our website. We are committed to protecting your interests against potential instances of money-laundering and related financial crimes and promoting legal and transparent trade in Digital Assets. This Anti-Money Laundering & Know-Your-Customer Policy (“AML & KYC Policy”) describes the policies and procedures relating to prevention of money laundering, financing of terrorism, and related illegal activities. The Company has prepared AML & KYC Policy to ensure the highest possible voluntary compliance under national and international AML standards.

This AML & KYC Policy applies uniformly to any User desirous of availing the Services or otherwise using or benefitting from the use the Website. It is imperative that you read this AML & KYC Policy before using the Website. By using the Website, you are expressly consenting to be bound by the Terms of Use and consequently this AML & KYC Policy. You must stop using our Services and/or the Website if your use results in committing/attempting to commit any criminal offences.

The terms “We”, “Our”, “Company” and “Us” refers to Global DCX Pte Ltd a private limited company incorporated in Singapore (hereafter referred to by its trading name, "Alluma"). The terms “User”, “You” and “Your” refer to a User of our Website. The capitalized terms used in this AML & KYC, but not defined herein, shall have the meaning given to such terms in the Terms of Use. For the purposes of relevant national and international laws and standards applicable from time to time, including the Monetary Authority of Singapore Act and its associated subordinate laws (collectively the “Act”), the Chief Officer in charge of AML can be reached at: [email protected]

Policy is part of our terms

This AML & KYC Policy is a part of and incorporated within, and is to be read along with, our Terms of Use (the “Terms”) and our Privacy Policy. You may view the current version of these policies, in effect from time to time, at www.alluma.io.

Unless otherwise specified, or required by reasonable or necessary implication, terms in this AML & KYC Policy have the same meaning as terms defined and used elsewhere in our Terms of Use. To avoid doubt, all provisions within our Terms of Use, including but not limited to, the General Terms, apply equally and uniformly to this AML & KYC Policy.

Consistent to Changes

We have the right, at any time, to change or modify the terms and conditions applicable to your use of our Services, or any part thereof (including this AML & KYC Policy), or to impose new conditions, including, but not limited to, adding fees and charges for use. Such changes, additions or deletions shall be effective immediately upon notice thereof. This notice may be given by means including, but not limited to, updating the “Last Updated” field at the top of this document with the date of the current revision.

Any use of our Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. Any amended Terms will apply prospectively to use of the Services after such changes become effective. It is important therefore that you review our Terms of Use and Privacy Policy on a regular basis to ensure that you are familiar with the terms in force from time to time and/or any changes made to them. If you do not agree to any amendments, you must discontinue using our Services and contact us to terminate your account.

Internal Controls

This AML & KYC Policy has been duly approved by our Audit Committee, which is empowered by the Board to oversee compliance with applicable AML Laws and Standards. We may regularly furnish regulators or law enforcement agencies the details of any transactions taking place on the Website and such other information as deemed necessary by us.

We will undertake a risk assessment based on (A) sufficiency and adequacy of identification documents submitted by you; (B) your social and/or financial status; (C) nature and other similar information about your business/vocational activities; or (D) guidance notes circulated by various governmental and inter- governmental organizations. We may internally categorize you as a low-risk, medium-risk, or a high-risk User on the basis of the aforementioned assessment.

We will keep your risk categorization and related data confidential at all times, subject to any requests received from a competent law enforcement authority. In order to maintain the integrity of the risk assessment process, the results of your risk assessment and/or categorization will not be disclosed to you either.

Customer Due Diligence/Know your Customer

You may either at the time of registering as a User; upon execution of any transactions; while requesting access to additional Services (such as increased buy and sell limits, requests to transfer any funds to your Linked Bank Account or third-party digital asset wallets, etc.); or periodically for purposes of updating records and on-going due-diligence (as specified under the AML Laws and Standards, or upon being directed by appropriate enforcement authorities), be required to take part in the User identification and verification process. For this purpose, we will follow the procedure prescribed under this Clause.

Required Customer Information

We may collect the following information for the purposes of verification of identification:

  • Individual Users.

    Name; date of birth; email address; phone number and residential address; photograph; copies or certified copy of any Valid Documents; documents pertaining to business/financial status of such User (if prescribed by the Company);

  • Business Users.

    Business name; name, contact-details, photograph, and copy of Valid Documents of the authorized representative, one certified copy each of the certificate of incorporation/registration Certificate (as the case may be); memorandum and articles of association/partnership deed (as the case may be); board resolution/other authorization documents giving authority to the representative chosen to execute transactions on the Website;

You must promptly update us of any changes to the customer information provided to us within three days of effecting such changes. You must file a fresh proof of address within three (3) months of effecting any changes to the address mentioned as per the ‘proof of address’ submitted by you.

Comparison with Government-Provided Lists

We may require you to furnish such other details as may be deemed necessary to verify your identity if we either (i) cannot verify your identity, or (ii) have a reason to believe that you are a person or entity whose details are provided in any official, governmental or intergovernmental sanction list. For the purpose of this AML & KYC Policy and our Terms of Use, “Sanction Lists” are lists maintained by us for the purposes of anti-money laundering compliance and include those circulated by the Financial Action Task Force (“FATF”), and the United Nations Security Council, including without limitation, the ISIL and Al-Qaida Sanctions List and the 1988 Sanctions List.

Alluma reserves the right to refuse registration to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time. Without limiting the generality of the foregoing, this includes, but is not limited to, anyone from or in jurisdictions that do not meet international AML–CTF standards as set out by the FATF; anyone that is a Politically Exposed Person within the meaning of the FATF’s 40 Recommendations; anyone on an official, governmental or intergovernmental Sanction Lists; upon reasonable request or direction of a competent enforcement authority; or, anyone that fails to meet any customer due diligence standards, requests, or requirements of Alluma.

If we believe any information obtained from the User hereunder is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; or (d) appearing on any Sanctions Lists, we may in our sole discretion either refuse or terminate (as the case may be) the registration of such Account or require such User to verify the Valid Documents submitted by it again. We may also, in our sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Website if we are unable to verify any information due to non-cooperation by the User, or if such transactions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.

Additional Information from Business Entities

In case of a legal entity, you must identify the Beneficial Owner and also assist in verification of the identity of such Beneficial Owner and any individual who purports to act on behalf of such legal entities. In this regard, a “Beneficial Owner” means: (A) In case of companies, the natural person who has ownership of over 25% (twenty five percent) of the shares, is entitled to over 25% (twenty five percent) of the profits, or has the power, directly or indirectly, to appoint or elect more than half of the board of directors of such company, as the case may be; and, (B) In case of partnership firms/Limited Liability Partnerships, the natural person(s) who has ownership of over 15% (fifteen percent) of the capital or is entitled to over 15% (fifteen percent) of the profits of such firm, as the case may be.

Reliance on Other Financial Institution

We may also require you to certify that your Linked Bank Account is held only with a scheduled commercial bank which is compliant with all know your customer (KYC) procedures mandated under the applicable laws. For this purpose, we may require you to furnish this certification in such format as may be prescribed by us.

Identity Verification Procedure

We may, at our sole discretion, at the time of initiation of your User registration process, request one or more appropriate third-party service provider to assist us in authentication and verification of the Valid Documents and other incidental details provided by you. In addition to the above, we reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We will use the following non-documentary methods of verifying identity: (a) Confirming validity of email; (b) Confirming validity of telephone number or bank account number; and (c) Confirming your location using, among others, your IP address; all of which may be carried out by an automated or manual process.

Monitoring and Mitigating Suspicious Activity

We may monitor and flag for review all transactions where the amounts involved exceed limits specified by local or applicable laws, official guidelines, or industry best practices. In addition to the above, we may regularly monitor, through both manual screening and use of software-based algorithms, all transactions executed and/or attempted to be executed on our Website, in order to promptly identify and highlight any suspicious activity, which includes without limitation, activities that:

  • appear, to a person acting in good faith, akin to collection of funds to be used, either in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts;

  • appear, to a person acting in good faith, to have been structured in a manner of unusual or unjustified complexity in order to avoid triggering any reporting requirements;

  • appear, to a person acting in good faith, to have been transacted for a malafide purpose or where a sound economic rationale cannot be

  • appear, to a person acting in good faith, to signal possible ‘money-laundering’ activities, as defined under applicable laws.

  • appear to be unusual due to the reason of being inconsistent with any User’s risk profile, expected usage pattern or sophistication. The extent of monitoring shall depend on various factors including upon each User’s risk

On detection of any suspicious activity, we reserve the right to take appropriate actions without any prior notification to the User, which includes, without limitation, (i) terminating the Account, (ii) restricting and/or blocking further access to our Website, and (iii) notifying the appropriate enforcement authorities regarding the suspicious activities of any User.

Maitenance of Records

  • Records of all transactions executed by you on our Website, for a period of at least 5 (Five) years from the date of each

  • Records of all suspicious transactions, trans-national transactions, and transactions wherein the amounts involved exceed US$ 750, whether executed or attempted, for a period of at least 10 (Ten) years, including but not limited to the information about the nature and value of the transactions, parties involved in such transactions, and information about the date of remittance, in addition to reporting the same

  • Identification records of Users (including but not limited to the Valid Documents submitted pursuant to the clause titled ‘Customer Due Diligence’ above), during the subsistence of and for a period of at least 5 (Five) years from the date of termination of such User’s

Disclosure and Notices

In order to improve the integrity and transparency of transactions on the Online Platforms, you are encouraged to report, to our Chief Compliance Officer, any information which you are privy to or become privy to, regarding any suspicious transactions, or transactions you find or have reason to believe are dubious in nature.

In order to ensure compliance with this AML & KYC Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as provided by you. Where you are required to share any information according to the procedures contained in this AML & KYC Policy, such communication may be made by you electronically by sending an email to our Chief Compliance Officer.

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