KYC & Anti Money Laundering (AML) Policy

Last updated: November 20, 2023

AML/KYC Policy

As a virtual currency provider, Globus Solutions Sp. z o.o (the: “Company“) must identify, assess, and understand the risks related to money laundering and terrorist financing. In addition, the Company reviews and examines each of its activities and applies measures to mitigate these risks. The applied measures by the Company are proportionate to the degree of identified risk. In the course of a risk-based approach, Globus Solutions Sp. z o.o assess the probability of the risks becoming real and the consequences of such an event. When assessing the probability, the possibility of the occurrence of the relevant circumstances must be taken into account, including the possibility of potential risks that may affect the activities of both the customer and the Company, and the possibility that the probability of the occurrence of this risk increases.

Globus Solutions Sp. z o.o is obligated to prepare a risk assessment in order to identify, assess and analyze the risks related to its client’s activity in regard to money laundering and terrorist financing and financial sanctions.

This model for the identification and management of risks relating to the customer and its activities is prepared to apply the obligations arising from clauses § 14 1) (2) and (6) of the RahaPTS in accordance with the general regulation provided by the Money Laundering and Terrorist Financing Prevention Act, the International Sanctions Act, and the Directive (EU) 2015/849 of the European Parliament and of the Council and includes:

Globus Solutions Sp. z o.o examines and classifies its customers based on the following three categories:

– Low risk (1 risk point)

No influential risk factors exist in any risk category, the customer itself and the customer’s activities are transparent and do not deviate from the usual activities, i.e., the activities of a reasonable and average person, in that field of activity, and there is no suspicion that the risk factors as a whole could lead to the realisation of the risk of money laundering or terrorist financing.

– Usual risk (2 risk points)

One or several risk factors exist in the risk category that deviate from the usual activities of a person acting in that field of activity, but the activity is still transparent and there is no suspicion that the risk factors as a whole could lead to the realisation of the risk of money laundering or terrorist financing.

C – High risk (3 risk points)

One or several risk factors exist in the risk category that as a whole grows suspicion of the transparency of the person and their activities, which causes the person to deviate from persons usually acting in that field of activity and it is at least possible that money laundering or terrorist financing is taking place.

As part of its on-going monitoring activities, Globus Solutions Sp. z o.o performs all due diligence measures as required by law. The extent of the implementation of the measures depends on the nature of the specific business relationship or transaction or the level of risk of the person or customer participating in the transaction or act, i.e., the “know your customer” principle must be followed. When determining and defining the risk levels of the customer or a person participating in the transaction, the Globus Solutions Sp. z o.o shall take into account, inter alia, the following risk categories:

  1. CUSTOMER-RELATED RISK
  1. RISK RELATED TO LEGAL NATURE OF CUSTOMER AND IDENTIFICATION OF BENEFICIAL OWNERS

A. Low risk is when the customer is:

B. Usual risk is when the customer is:

C. High risk is when:

1.2  RISK RELATED TO THE COUNTRIES OR GEOGRAPHIC TERRITORIES OR JURISDICTIONS

A. Low risk is when:

B. Usual risk is when the location of the customer is in a third country not listed above, excluding a third high-risk country;

C. High risk is considered in circumstances where the risk is primarily increased in such an event where the customer, person participating in a transaction or the transaction itself is related to a country or jurisdiction which, based on the trustworthy sources in the country like mutual assessments, detailed assessment reports or published follow-up reports, has no valid and efficient systems of the prevention of money laundering and terrorist financing. According to the Commission Delegated Regulation (EU) 2016/1675 (Appendix 13), the third high-risk countries include Afghanistan, Bosnia and Herzegovina, Guyana, Iraq, Lao PDR, Syria, Uganda, Vanuatu, Yemen, Iran, and DPR Korea. The list of countries as determined by the FATF belonging to third high-risk countries is disclosed on the following webpage: http://www.fatf-gafi.org/countries/#high-risk. Additionally, the following countries or jurisdictions indicate of a high risk customer, person participating in a transaction or transaction itself:

1.3   RISK RELATED TO CUSTOMER’S ACTIVITY AND TO PROVIDED  

                       PRODUCTS OR SERVICES

A. Low risk is when the customer is a person performing usual and normal economic and professional activities and the turnover of the financial instruments of the customer, or the planned turnover of the financial instruments, is significantly small and does not exceed 40 000 euros per one year;

B. Usual risk is when the customer is a person performing usual and normal economic and professional activities and the turnover of the financial instruments of the customer, or the planned turnover of the financial instruments, exceeds 40 000 euros per one year;

C. High risk is when the business relationship takes place under unusual circumstances, including when the transactions are complicated and have unusually large scale, when the transaction patterns are unusual, or when the customer is a legal entity or another association of persons that does not have the status of a legal entity, if their economic activity does not have a reasonable and clear economic or lawful objective or it is not characteristic of a specific business field or if the customer’s activity includes any of the following, regardless of the amount of the turnover:

1.4   RISK RELATED TO BILLING AND TRANSACTIONS

A. Low risk is when:

B. Usual risk is when the customer uses the following during transactions with the Company

C. High risk is when the customer uses the following during transactions with the Company:

 1.5  RISK ARISING FROM POLITICALLY EXPOSED PERSON

A. Low risk is when the customer is not a politically exposed person, the family member of the politically exposed person or a person known to be the close associate of the customer who is a politically exposed person;

B. Usual risk is when the customer is a politically exposed person, the family member of the politically exposed person or a person known to be the close associate of the customer. In such a case, the due diligence measures provided for in section 41 of the RahaPTS are applied in addition to the usual due diligence measures. The background of the customer is verified primarily by:

C. High risk is when the customer is a politically exposed person, the family member of the politically exposed person or a person known to be the close associate of the customer. In such a case, the due diligence measures provided for in section 41 of the RahaPTS are applied in addition to the usual due diligence measures. The background of the customer is verified primarily by:

1.6 RISK RELATED TO IDENTIFICATION OF CUSTOMER.

A. Low risk is when:

B. Usual risk is when:

C. High risk is when:

1.7 RISK RELATED TO CHANNELS OF COMMUNICATION OR  

       TRANSMISSION BETWEEN THE COMPANY AND THE CUSTOMER.

A. Low risk is when:

B. Usual risk is when:

C. High risk is when:

Taking into account the above risk categories, Globus Solutions Sp. z o.o determines the risk level of the person involved in the transaction or the customer, for example whether the customer’s money laundering or terrorist financing risk is low, normal, or high or corresponds to other risk levels specified and used by the Company.

In order to determine the impact of each risk category, Globus Solutions Sp. z o.o assesses the probability of the occurrence of risk factors in that risk category. To determine the impact of a particular risk category, a qualifying amount of the presence of risk factors that characterize it can be used to consider a particular risk factor as having “impact” or “no impact” for a given person when a certain threshold is exceeded.

Instructions for defining low level of risk:

Instructions for defining high level of risk:

Globus Solutions Sp. z o.o shall document, update, and disclose the determination of the level of risk to the competent authorities if necessary.

Globus Solutions Sp. z o.o are primarily related to the handling and storage of currencies ​​presented in a digital form. The provision of a service of exchanging a virtual currency against a fiat currency and a virtual currency wallet service primarily requires the use of new and evolving technologies, which may involve the implementation of new or non-traditional sales channels within the economic activities of the Company. The vast majority of virtual currencies are comprised of different cryptocurrencies and related tokens, built on a new and rapidly evolving blockchain technology and a distributed database that is updated through a mathematical consensus algorithm.

This assessment is mainly the result of the following factors:

  1. Block-chain technology is new and evolving, so the mechanisms and algorithms for its occurrence, existence, transfer, and trading are not constant and may be too complex to understand. This encourages the involvement and use of virtual currencies, including cryptocurrency, in various fraudulent schemes and scams;
  2. Block-chain technology promotes anonymity (cryptocurrency wallet addresses are not personalized and exist usually in large quantities), which may involve the use of virtual currencies, including cryptocurrency, in money laundering, tax evasion, terrorist financing or criminal schemes;
  3. Block-chain technology is based on a P2P network and is not regulated by any central organizations which may facilitate the manipulation of the value of virtual currencies, including cryptocurrency.

This risk analysis, risk mitigation method and the definition of risk appetite defined by Globus Solutions Sp. z o.o as a provider of service of exchanging a virtual currency against a fiat currency and a virtual currency wallet service have been prepared in order to fulfil the obligation arising from the RahaPTS in view of the general risk associated with the Company’s activities.

Globus Solutions Sp. z o.o is obliged to inform the employees of the company on an ongoing basis about changes in the risk assessment arising from the Company’s activities and changes in the company’s long-term and short-term doctrine and separate viewpoints and instructions (according to the market situation, the political and economic situation, the arrangements of the supervisory authorities, etc) in order to comply with the provisions of the RahaPTS. This information and these notices do not necessarily have to be in the form of appendices to these guidelines and may be provided at meetings, through the heads of structural units, via e-mail or orally, but regardless of the method of transmission, it is mandatory to comply with and follow this information and these notices.

  1. RISK RELATED TO ACTIVITIES OF THE COMPANY AND NATURE OF SERVICES PROVIDED

The following lists the risk factors and circumstances related to the customer’s degree of risk arising from the nature and volume of services provided by Globus Solutions Sp. z o.o to the customer.

A. Low risk is when:

B. Usual risk is when:

C. High risk is when:

  2.    MITIGATION OF RISKS

Given that money laundering, terrorist financing and support for criminal activities generally has a cause and is effective when dealing with larger amounts of money than usual, Globus Solutions Sp. z o.o shall, in addition to the due diligence measures set out in these guidelines, impose the following restrictions on the volume of business transactions:

 3.    RISK APPETITE

Globus Solutions Sp. z o.o shall not enter into business relations with persons who are prohibited by these guidelines and its appendices or laws and/or who are suspected by the Company of using the its services for money laundering, tax evasion, terrorist financing or criminal schemes, but shall not create additional barriers to the use of services by customers for whom there are no such doubts.  

Globus Solutions Sp. z o.o shall avoid business relations in particular with the following categories of customers:

      4.   CUSTOMER IDENTIFICATION SPECIFICATIONS

Globus Solutions Sp. z o.o has established numerous measures in order to identify the identity of a customer, in addition to the provisions provided for in § 21 (3) or § 22 (3) of the RahaPTS which require meeting the customer face-to-face, in such a way that enables identification of the customer without being in the same place. In such a case, the customer shall deliver the original identity document to Globus Solutions Sp. z o.o in the form that is authenticated by a notary or certified by a notary or officially.

Alternatively, the possibility provided for in § 21 (4) or § 22 (4) of the RahaPTS shall be used to identify the customer on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.

Globus Solutions Sp. z o.o shall mainly use two sources from the following list:

The procedures containing additional details for the customer identification based on the information from other reliable and independent sources shall be established in the rules of procedure.