1. Introduction
The Anti-Money Laundering and Know Your Customer (hereinafter referred to as the “AML/KYT/KYC Policy”) policy is designed to prevent and mitigate 1Mile's possible risks of being involved in any illegal activity.
2. Purpose of internal regulation
The service adheres to practices and measures in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that 1Mile takes seriously any attempt to use its service for illegal purposes.
3. Caution
The 1Mile Service warns users against attempting to use the Service for money laundering, terrorist financing, fraud of any kind, as well as from using the Service to purchase prohibited goods and services.
The 1Mile service, its administration, employees and domain owners are not responsible for the misuse of the service by third parties, the actions of intruders and possible damage associated with the use of the service.
4. Requirements
To prevent illegal transactions, the 1Mile service sets certain requirements for all Applications created by the User:
4.1. The sender and recipient of the Payment under the Application must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited.
4.2.All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.
4.3. It is strictly forbidden to create Applications by the User using anonymous proxy servers, VPN, Tor or any other anonymous Internet connections.
5. Verification Procedures
One of the international standards for the prevention of illegal activities is customer due diligence (hereinafter - Verification). To this end, 1Mile implements its own verification procedures against stringent anti-money laundering and Know Your Customer procedures.
5.1. The 1Mile Service may require the User to provide the Service with reliable, independent source documents, data or information (for example, a national ID card, an international passport, a bank statement). For such purposes, the 1Mile Service reserves the right to collect User identification information for the purposes of complying with the AML/KYC Policy.
5.2. The 1Mile Service will take steps to verify the authenticity of documents and information provided by Users. All legal methods to double check identity information will be used and the Service reserves the right to investigate cases of certain Users whose identities have been identified as dangerous or suspicious.
5.3.1Mile Service reserves the right to verify the identity of the User on an ongoing basis, especially when his identification information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the 1Mile Service reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.
5.4. User identification information will be collected, stored, shared and protected strictly in accordance with the 1Mile Privacy Policy and related policies.
5.5. After confirming the identity of the user, the 1Mile Service may refuse to provide services to the User in a situation where the services of the Service are used to conduct illegal activities.
5.6. Users who intend to use payment cards for the purpose of consuming services must complete card verification in accordance with the instructions available on the 1Mile website.
5.7. The 1Mile Service has regulatory requirements to verify the source of funds or cryptocurrencies in order to know that the source of funds that Users use to trade is legal.
5.8. The service reserves the right not to provide the user with information about the reasons of carrying out of check, used methods and its results.
6. Responsible Official
The AML Compliance Officer is the person duly authorized by the 1Mile Service, whose responsibility is to ensure that the AML/KYC policy is effectively implemented and enforced.
6.1. The duty of such officer is to oversee all aspects of 1Mile's anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods:
- collection of user identification information;
- establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required by applicable laws and regulations;
- monitoring transactions and investigating any significant deviations from normal activities;
- implementation of a records management system for the appropriate storage and retrieval of documents, files, forms and logs;
- regular updating of the risk assessment;
- providing law enforcement authorities with the information required by applicable laws and regulations.
6.2. The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.
7. System functions
1Mile performs many compliance tasks, including data collection, filtering, record keeping, investigation management, and reporting.System features include:
- Checking Users daily for the existence of recognized "blacklists" (e.g. OFAC), aggregating transfers across multiple data points, placing users on watchlists and denial of service lists, opening cases for investigation where appropriate, sending internal messages and filling mandatory reporting, if applicable;
- business and document management.
8. Behavior analysis
The 1Mile Service verifies Users not only by verifying their identity, but more importantly by analyzing their behavior in transactions. Therefore, the Service relies on data analysis as a risk assessment and suspicion detection tool.
9. Risk assessments
1Mile, in accordance with international requirements, applies the practice of risk assessment to combat money laundering and terrorist financing. By applying the practice of risk assessment to combat money laundering, the Service ensures that measures to prevent or reduce money laundering and terrorist financing are commensurate with the identified risks.
10. Perform customer checks
If there are reasonable suspicions from the administration of the 1Mile service that the user is trying to use the services of the Service for money laundering or for the purpose of carrying out any other illegal operations, the administration has the right to:
10.1. suspend the user's exchange operation;
10.2. request from the User identification documents;
10.3. request from the User any additional information and documents in case they carry out suspicious transactions;
10.4.ensure that reports of suspicious nature of transactions are forwarded to the appropriate law enforcement authorities through the AML Compliance Officer.
11. Privacy
The 1Mile service guarantees the client's privacy in accordance with the service's privacy policy.
11.1. 1Mile Service and its employees are committed to maintaining the confidentiality of any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom information on the transaction was transferred.
11.2. The confidentiality obligation imposed on employees of the 1Mile Service remains in force after the termination of their work or any other contractual relationship with the Service, as well as when such employees are transferred to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases specified by law is not a violation of confidentiality obligations.
11.3. The obligation to maintain confidentiality, provided that the use of disclosed information is limited to preventing the legitimization of proceeds of crime and terrorist financing, cannot apply to disclosures between financial institutions that form a consolidated group that cooperates with the 1Mile Service.
12. Conclusion
In connection with the foregoing, the 1Mile service does not bear any legal responsibility for using it to launder money obtained by criminal means, finance terrorism or purchase prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the Service for the purpose of legalizing money obtained by criminal means, financing of terrorism or the purchase of prohibited goods and services.
