ILERITER sp. z o.o. is committed to implementing appropriate anti-money laundering and counter-terrorist financing ("AML/CFT") measures in relation to the operation of the Platform and in accordance with applicable legal and regulatory requirements. Where regulated crypto-asset services are provided by a CASP Partner, the relevant CASP Partner remains independently responsible for complying with its own AML/CFT obligations under applicable law.
ILERITER sp. z o.o. reserves the right to amend or supplement its internal AML/CFT procedures from time to time in order to comply with changes in applicable law, regulatory guidance, or evolving financial crime risks. Such internal procedures may be more detailed than the general principles described in this Policy.
Money laundering involves disguising the illicit origins of assets or obstructing their traceability through the Platform or services made available through the Platform. Similar AML regulations are mandatory for comparable businesses in Poland and other countries, as money laundering and terrorism financing are often carried out on an international scale.
ILERITER sp. z o.o. and, where applicable, the relevant CASP Partner conduct sanctions screening and other compliance measures in accordance with their respective legal and regulatory obligations.
For the purposes of this Policy, the AML Act refers to the Act of March 1, 2018, on Counteracting Money Laundering and Financing of Terrorism (the “AML/CFT Act”), which addresses measures against the legalization of revenues from criminal activities and terrorism financing.
ILERITER sp. z o.o. has appointed a Compliance Officer and MLRO responsible for implementing the Company's internal AML/CFT compliance framework applicable to the operation of the Platform.
Nothing in this Policy shall be interpreted as limiting or replacing the independent AML/CFT policies, procedures, or legal obligations of any CASP Partner providing regulated crypto-asset services.
DEFINITIONS:
"CASP" means a Crypto-Asset Service Provider authorised under Regulation (EU) 2023/1114 on Markets in Crypto-Assets ("MiCA").
"CASP Partner" means an independent licensed CASP that provides regulated crypto-asset services through or in connection with the Platform.
"Platform" means the Platform operated by ILERITER sp. z o.o., available at cryptoramper.io, through which Users may access the Services and certain services provided by third-party partners.
"AML/CFT" means anti-money laundering and counter-terrorist financing measures, including all applicable laws, regulations, sanctions requirements, and other measures aimed at preventing money laundering, terrorist financing, proliferation financing, fraud, and other financial crimes.
"Compliance Officer" means the individual appointed by ILERITER sp. z o.o. to oversee and implement the Company's internal AML/CFT compliance framework applicable to the operation of the Platform.
"MLRO" (Money Laundering Reporting Officer) means the individual appointed by ILERITER sp. z o.o. who is responsible for overseeing the Company's AML/CFT compliance framework, receiving and assessing reports of suspicious activities, liaising with competent authorities where required, and performing such other functions as may be required under applicable AML/CFT laws and regulations.
AML PROTOCOLS
ILERITER sp. z o.o. applies the following AML/CFT protocols in relation to the operation of the Platform. Where regulated crypto-asset services are provided by a CASP Partner, the relevant CASP Partner applies its own AML/CFT policies and procedures in accordance with applicable law:
1. Client Identity Verification: We perform identity verification where required in connection with the Platform. Where the requested regulated crypto-asset service is provided by a CASP Partner, the relevant CASP Partner may independently perform identity verification and additional customer due diligence in accordance with its own legal and regulatory obligations.
2. Risk-Based Client Due Diligence: We implement and maintain a client due diligence system that is tailored to the assessed risk level, applying increased scrutiny for clients identified as higher risk, and, where applicable, the relevant CASP Partner may apply its own risk assessment and enhanced due diligence measures independently of ILERITER sp. z o.o.
3. Transaction Monitoring: Transaction monitoring is carried out by ILERITER sp. z o.o. and/or the relevant CASP Partner, depending on the nature of the Service and the applicable legal and regulatory obligations.
4. Reporting Suspicious Activity: ILERITER sp. z o.o. reports suspicious activities where required by applicable law. The relevant CASP Partner remains independently responsible for fulfilling its own reporting obligations under applicable AML/CFT legislation.
5. Regular AML Training: ILERITER sp. z o.o.conducts regular and comprehensive AML training sessions for our team members to ensure they are updated on the latest protocols and practices.
6. Cooperation with CASP Partners: ILERITER sp. z o.o. may cooperate and exchange information with CASP Partners, payment service providers, identity verification providers, blockchain analytics providers, and competent authorities where necessary to comply with applicable AML/CFT laws, prevent financial crime, and fulfil legal or regulatory obligations.
IDENTITY VERIFICATION PROCESS
To maintain the integrity of the Platform and comply with applicable legal and regulatory requirements, ILERITER sp. z o.o. may verify the identity of Users before granting access to certain Services. Where regulated crypto-asset services are provided by a CASP Partner, the relevant CASP Partner may independently conduct identity verification and customer due diligence in accordance with its own legal and regulatory obligations. This process is crucial for preventing terrorism financing and money laundering. Applicable laws may require ILERITER sp. z o.o. and/or the relevant CASP Partner to collect, verify, and maintain customer identification information before providing certain Services. ILERITER sp. z o.o. and/or the relevant CASP Partner may require your name, address, date of birth, and other relevant details about you, your organization, or associated individuals before processing any transactions. Where a User is assessed as presenting a higher level of AML/CFT risk, ILERITER sp. z o.o. and/or the relevant CASP Partner may conduct enhanced due diligence, request additional information or documentation, and extend the verification process where necessary. ILERITER sp. z o.o. and/or the relevant CASP Partner may conduct ongoing customer due diligence and periodically request updated information or documentation where required by applicable law or where the User's risk profile changes. ILERITER sp. z o.o. and/or the relevant CASP Partner may request updated documents from the customer even if previous verifications have been completed. All collected identification information will be managed in strict accordance with ILERITER sp. z o.o.'s Privacy Policy and relevant regulations, ensuring that it is securely collected, stored, and shared. Where personal data is collected or processed by a CASP Partner, such processing shall also be governed by the applicable privacy policy of the relevant CASP Partner.
IDENTITY VERIFICATION REQUIREMENTS
Depending on the nature of the requested Service and applicable legal or regulatory requirements, Users may be required by ILERITER sp. z o.o. and/or the relevant CASP Partner to provide the following information and documentation:
· Full name.
· State-assigned identification number (supported by documents such as a photocopy of a national ID, international passport, or other identification documents).
· Date of birth.
· Nationality.
· Telephone number.
· Email address.
· Address (supported by documents such as a bank statement and a utility bill as proof of address).
· Other information or documents reasonably requested by ILERITER sp. z o.o. and/or the relevant CASP Partner to comply with applicable legal, regulatory, AML/CFT, sanctions, fraud prevention, or compliance requirements.
Where enhanced due diligence or additional verification is required, ILERITER sp. z o.o. and/or the relevant CASP Partner may request additional documentation relating to the User's identity, address, source of funds, source of wealth, business activities, or financial status, as appropriate.
The additional documents required are:
For Individuals:
· Identity Document: A color copy of a passport or another recognized identity document from the user's country of residence.
· Government-Issued Document: A document such as a tax statement that clearly shows the individual's residential address, or another document reasonably accepted by ILERITER sp. z o.o. or the relevant CASP Partner.
· Bank Statement: A statement dated within the last 3 months.
· Utility Bill: A bill dated within the last 3 months.
For Legal Entities:
· Corporate Documentation: A copy of the extract from the protocol of the general meeting of participants/shareholders, a certificate of directors and secretary, minutes of the first meeting of directors, a register of directors, or another document verifying the appointment of directors or equivalent documentation confirming the registration of corporate acts and amendments and the authority of the company head.
· Head's Identity Document: A copy of the passport of the company head (or passport copies of all individuals who, directly or indirectly, own more than 25 percent of the company's share capital, if required).
· Location Confirmation: A document verifying the legal entity’s location or business address (such as a utility bill dated within the last 3 months or a copy of the office rental agreement).
· Certificate of Incorporation: A copy of the certificate of incorporation.
· Memorandum and Articles of Association: A copy of the memorandum and articles of association or an equivalent document, duly registered with the appropriate authority.
· Shareholders Certificate: A certificate of shareholders or a register of members.
· Bank Reference Letter: A reference letter from the bank confirming the opening of a current account, or a copy of the bank contract for account opening.
· Certificate of Good Standing: A copy of the certificate of good standing.
Additional corporate documentation may be requested where reasonably necessary to identify beneficial ownership, verify the ownership and control structure, assess the legitimacy of business activities, or comply with applicable AML/CFT obligations.
The scope of information and documentation required may vary depending on the User's risk profile, jurisdiction, the requested Service, applicable legal and regulatory requirements, and the internal compliance procedures of ILERITER sp. z o.o. and/or the relevant CASP Partner.
RISK ASSESSMENT
ILERITER sp. z o.o. applies a risk-based approach in accordance with applicable AML/CFT laws and regulations. Where regulated crypto-asset services are provided by a CASP Partner, the relevant CASP Partner applies its own independent risk assessment methodology and customer risk classification in accordance with its legal and regulatory obligations.
Risk assessments may be reviewed and updated on an ongoing basis based on new information, changes in customer activity, transaction behaviour, geographic exposure, regulatory developments, sanctions, or other relevant risk factors.
Risk Categories:
1. Customer-Related Risk Suspect Indicators:
These may include inconsistencies in identification documents, fictitious or stolen identities, counterfeit documentation, use of PO box addresses, previous involvement in financial crimes, links to terrorism, individuals with outstanding warrants, lack of valid contact information, and discrepancies in legal entity documents. The presence of one or more risk indicators does not automatically result in the refusal of Services but may require enhanced due diligence, additional verification, or ongoing monitoring by ILERITER sp. z o.o. and/or the relevant CASP Partner.
Politically Exposed Persons (PEPs):
This category includes individuals holding prominent public positions such as heads of state or government, ministers, members of parliament, members of political party governing bodies, supreme court judges, ambassadors, high-ranking military officials, directors of state-owned enterprises, and directors of international organizations. Users identified as PEPs, their family members, or close associates may be subject to enhanced due diligence in accordance with applicable AML/CFT requirements.
2. Country-Related Risk:
The Anti-Money Laundering Directive requires enhanced due diligence for business relationships or transactions involving high-risk third countries. This involves obtaining additional information about the customer and beneficial owner, the source of funds and assets, the purpose of the transaction, and securing senior management approval to initiate or continue the relationship. The relevant CASP Partner may independently determine whether a jurisdiction presents an unacceptable level of AML/CFT risk and may refuse or restrict the provision of regulated crypto-asset services accordingly.
This risk-based approach enables ILERITER sp. z o.o. to identify, assess, and mitigate AML/CFT risks relating to the operation of the Platform. It does not replace or limit the independent AML/CFT obligations of any CASP Partner providing regulated crypto-asset services.
CLASSIFICATION OF CLIENTS BY RISK LEVEL
The classification below is indicative only. The final risk classification assigned to a User may depend on the overall assessment performed by ILERITER sp. z o.o. and/or the relevant CASP Partner, taking into account all available information and applicable legal and regulatory requirements.
Low-Risk Clients:
- Clients residing in a member state of the European Union, a member state of the European Free Trade Association (EFTA), or a party to the European Economic Area (EEA) Agreement.
- Clients residing in a third country recognized by reputable sources as having low levels of corruption or other criminal activities.
- Clients residing in a third country where strong Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT) regulations are effectively implemented.
Classification as a low-risk User does not eliminate the requirement to complete customer due diligence or ongoing monitoring where required by applicable law.
High-Risk Clients:
- Clients whose identity information's authenticity, validity, or integrity is in question.
- Clients from or located in high-risk third countries.
- Clients identified as Politically Exposed Persons (PEPs).
- Transactions that are deemed unusual.
- Clients exhibiting suspicious behavior that raises concerns about potential misconduct.
- Users whose source of funds or source of wealth cannot be satisfactorily verified.
- Users subject to international sanctions or associated with sanctioned persons or jurisdictions.
- Users whose transaction activity is inconsistent with their declared profile or expected behaviour.
Users classified as high-risk may be subject to enhanced due diligence, additional identity verification, source of funds and source of wealth verification, senior management approval, ongoing transaction monitoring, or other risk mitigation measures considered appropriate by ILERITER sp. z o.o. and/or the relevant CASP Partner.
Nothing in this Policy shall prevent ILERITER sp. z o.o. or the relevant CASP Partner from declining to establish or continue a business relationship, restricting access to Services, suspending transactions, or terminating the relationship where required by applicable law or where AML/CFT risks cannot be adequately mitigated.
CONTACT US:
If you have any questions regarding this AML/KYC Policy, our AML/CFT procedures, identity verification requirements, or the processing of your information for AML/CFT purposes, please contact us using the details below.
You can also contact us via email at info@cryptoramper.io. We're here to assist you.
Where your enquiry relates specifically to regulated crypto-asset services provided by a CASP Partner, identity verification carried out by a CASP Partner, or decisions taken by a CASP Partner under its AML/CFT obligations, you may also be required to contact the relevant CASP Partner directly in accordance with its own policies and procedures.
