Self-Action Program against money laundering

Company CRYPTOVEA, Inc.  (hereinafter referred to as the "Company") providing the "Provision of Virtual Currency Wallet Services" is  (pursuant to Act no. 297/2008 Coll. on protection against money laundering)  liable person performing the activities specified in the Act.

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Due to the performance of the said trade according to the subject of its activity, the company is obliged to develop and update Self-Action Program against money laundering.

 

The aim of elaboration and subsequent compliance with the program is the methodology, harmonization of internal guidelines and programs of the company with the current legal order of the Slovak Republic and last but not least the prevention and detection of unusual business operations and the introduction of a control mechanism in the company for company employees.

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The main feature of the Cryptove platform is to be a legal, transparent and reliable partner in the field of financial investment. In order not to be associated with fraudulent and dubious institutions, Cryptovea:

• never offers its services by phone

• never promise a quick return and a safe investment expressed in fiat currencies

• offers are not limited in time

• offers are not just for you and we do not ask you not to tell anyone about them

• never asks for passwords or any access data to your accounts

• does not work with cash

 

This Self-Actionn Program includes, in accordance with the law:

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1) the content and schedule of staff training at least once a year,

2) identification of the person or organizational unit responsible for protection against legalization

3) overview of forms of unusual business operations and definition of risks

4) defining politically exposed persons

5) defining end-user benefits

6) identification

7) verification of identification

8) care of the liable person in relation to the client

9) procedure for detecting an unusual business operation

10) method of data processing and storage

11) method of ensuring the protection of an employee who detects unusual business operations

12) method of performing control of compliance with the Self-Action Program and the obligations arising from this Act for the liable person

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1• Content and schedule of staff training

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The company continuously organizes trainings, lectures and professional trainings, the aim of which is to provide employees and the company's management with a comprehensive overview and the opportunity to obtain professional information on the development of the applicable Slovak legislation concerning the company's business activities.

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The organization and time schedule of the above forms of employee training is subject to current changes in Slovak legislation.

 

The date of the above activities is no later than the end of the 6th month of the given calendar year, about which the company's employees will be continuously informed and also about the content and content of the mentioned trainings, lectures and professional trainings.

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year 2022 – date: 15. 06. 2022

year 2023 – date: 15. 06. 2023

year 2024 – date: 12. 06. 2024

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Content of lectures: Analysis, interpretation and application of Act no. 297/2008 Coll. on protection against money laundering in connection with Acts no. 372/1990 Coll. on offenses, no. 300/2005 Coll. Criminal Code, no. 301/2005 Coll. Criminal Procedure Code, no. 428/2002 Coll. on the protection of personal data

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2• Person responsible for protection against legalization

 

The person responsible in the company for protection against legalization is Ing. Šurin Peter, bytom Jankovce 39 (statutory representative of the company). The responsible person manages and directs the activities of other employees regarding compliance with the Program of their own activities. At the same time, it is responsible for updating the Program of its own activities in accordance with the applicable legislation.

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3• Overview of forms of unusual business operations and definition of risks

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• natural or legal person - acting as a business partner - is not registered in the business, or. trade register or other register / list of entities with legal personality and there is no possibility to reliably verify the data on the business partner - business partner - natural or legal person - originating from non-EU and OECD member states

• a business which, because of its complexity, unusually high volume of funds or other nature, clearly deviates from the normal framework or nature of a particular type of business or business of a particular client

• a business which, by reason of its complexity, unusually large amount of funds or other nature, has no obvious economic purpose or obvious legal purpose

• a transaction in which the client refuses to identify or provide the data necessary for the performance of care by the liable person

• a transaction in which the client refuses to provide information about the planned transaction or tries to provide as little information as possible or provides such information that the liable person can check with great difficulty or only at great expense

• a business in which the client requests its execution on the basis of a project that raises doubts

• a trade in which disproportionately large amounts of funds of low denomination are used

• business with a client for whom it can be assumed that due to his employment, position or other characteristics he is not or cannot be the owner of the necessary funds

• a trade in which the volume of funds available to the client is in a manifest disproportion to the nature or scope of his business or to the declared ownership

• a trade in which there is a reasonable presumption that the funds or assets are to be or have been used for terrorist financing

• a trade in which there is a reasonable presumption that its end-user of the benefits is a person who raises or provides funds or property for the purpose of terrorist financing

• trade which takes place from or to the country in whose territory the terrorist organizations operate or which provides funds or other support to the terrorist organizations

• a business in which there is a reasonable presumption that the client or end-user of the benefits is a person subject to an international sanction under a special regulation or a person who may be in relation to that person

• a trade in which there is a reasonable presumption that its object is or is to be an object or service which may be related to an object or service which is subject to an international sanction pursuant to a special regulation

• the business relationship takes place under unusual circumstances

• clients located in higher risk geographical areas

• legal persons or persons without legal personality who are the means of possession of personal property

• companies in which authorized shareholders may operate or companies that issue bearer shares

• a client who is a third-country national who applies for a right of residence or citizenship in a Member State in exchange for capital transfers, the purchase of assets or government bonds, or for investments in businesses in that Member State

• the client uses cash intensively in its business activities

• the client's ownership structure appears to be unusual or overly complex given the nature of its business

• countries identified by the European Commission as high-risk and countries which, according to credible sources, do not have effective anti-money laundering or anti-terrorist financing systems,

• countries identified on the basis of credible sources as having a high level of corruption or other criminal activity,

• countries which are subject to sanctions, embargoes or similar measures issued by, for example, the European Union or the United Nations, or

• countries providing funding or support for terrorist activity or countries in which identified terrorist organizations operate

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4• Defining politically exposed persons

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A politically exposed person means a natural person who is or has been entrusted with a significant public function:

Paragraph 1:

• Head of State, Prime Minister, Deputy Prime Minister, Minister, Head of the Central State Administration Body, State Secretary or similar Deputy Minister

• Member of the Legislature

• Judge of the Supreme Court, Judge of the Supreme Administrative Court, Judge of the Constitutional Court or other judicial bodies of higher instance, against which decisions can no longer be appealed except in special cases, Chairman of the Judicial Council, Vice-Chairman of criminal court, president of a regional court, vice-president of a regional court, president of a district court or vice-president of a district court

• Member of the Court of Auditors or of the Central Bank Board

• Ambassador, chargé d'affaires

• Senior member of the armed forces, armed forces or armed security forces

• Member of the management body, supervisory body or supervisory body of a state-owned enterprise or commercial company owned by the state

• Prosecutor General, Deputy Prosecutor General, Special Prosecutor, Deputy Special Prosecutor, Regional Prosecutor, Deputy Regional Prosecutor, District Prosecutor or Deputy District Prosecutor

• Person in another similar function of national or regional significance or another similar function performed in the institutions of the European Union or in international organizations

• Member of the statutory body of a political party or political movement

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For the purposes of this Act, a politically exposed person also means a natural person who is

• the spouse or a person having a similar status to the spouse of the person referred to in paragraph 1

• the child, son-in-law, bride of the person referred to in paragraph 1 or a person who has a similar status to the son-in-law or bride of the person referred to in paragraph 1

• parent of the person referred to in paragraph 1

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For the purposes of this Act, a politically exposed person also means a natural person who is known to be the end user of the benefits.

• the same client or otherwise controls the same client as the person referred to in paragraph 1 or does business with the person referred to in paragraph 1

• a client who has been set up for the benefit of a person referred to in paragraph 1

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5• Defining end-user benefits

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Paragraph 1) The end user of the benefits is any natural person who actually controls or controls the legal person, natural person - entrepreneur or association of property, and any natural person for whose benefit these entities carry out their activity or business. The end users benefits in particular

• a) in the case of a legal person which is not an association of assets or an issuer of securities admitted to trading on a regulated market, which is subject to disclosure requirements under a special regulation, equivalent legislation of a Member State of the European Union or another State party to the Agreement on the European Economic Area (hereinafter referred to as a "Member State") or equivalent international standards, a natural person

  • ​has a direct or indirect share or a total of at least 25% of the voting rights in the legal entity or its share capital, including bearer shares

  • has the right to appoint, otherwise appoint or remove a statutory body, a management body, a supervisory body or a supervisory body in a legal person or any of its members

  • controls the legal person in a manner other than that referred to in the first and second points

  • has the right to an economic benefit of at least 25% from the legal person's business or other activities

• ​b) in the case of a natural person-entrepreneur, a natural person who has the right to economic benefit of at least 25% of the business of a natural person-entrepreneur or other activities

• c) in the case of an association of assets, the natural person who

  • is the founder or founder of an association of property; if the founder or founder is a legal person, a natural person according to letter a)

  • has the right to appoint, otherwise appoint or remove the statutory body, management body, supervisory body or supervisory body of the association of property or their member or is a member of the body which has the right to appoint, otherwise appoint or remove these bodies or their member

  • is a statutory body, a managing body, a supervisory body, a supervisory body or a member of those bodies

  • is the recipient of at least 25% of the funds provided by the pool of assets, if future recipients of these funds have been identified; if no future beneficiaries of the funds of the pool of assets have been identified, the end-user is considered to be a group of persons who have a significant benefit from the establishment or operation of the pool of assets

 

Paragraph 2) If no natural person meets the criteria set out in paragraph 1 letter. (a) members of its top management shall be considered as end-users of that person's benefits; the statutory body or members of the statutory body are considered to be a member of the top management

 

Paragraph 3) The end user of benefits is also a natural person who does not meet the criteria under paragraph 1 letter. a), b) or letter (c) the second and fourth points, but together with another person acting in concert or joint action, meets at least some of the following criteria:

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6• Identification

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Identification means, in the case of a natural person, the identification of the name, surname, birth number or date of birth, if no birth number has been assigned, address of permanent residence or other residence, nationality, identification of the type and number of the identity document. CRYPTOVEA, Inc. currently provides services only to individuals and legal entities. It does not provide services to agents and minors.

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Based on the risk assessment, the liable person may, in addition to the above data, request other data, such as telephone number, e-mail address, employment data or employer.

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For the purposes of this Act, the identification of the end user of benefits means the determination of the name, surname, birth number or date of birth, if a birth number has not been assigned, the address of permanent residence or other residence and nationality.

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7• Identification verification

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For the purposes of this Act, verification of identification means verification of the obtained data with the data in his / her identity document, if they are stated there, and verification of the form of the person with his / her identity in his / her physical presence or using his / her own company technical means. verification similar to physical presence verification.

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The liable person is obliged to verify the identification of the client who is a natural person before concluding a business relationship or executing a business.

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8• Care of the liable person in relation to the client

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Basic care

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The basic care of the liable person in relation to the client includes

• identification of the client and verification of his identification

• identification of the end-user of benefits and taking appropriate measures to verify the information concerning the identification of the end-user of benefits.

• determining whether the client or the end user of the client's benefits is a politically exposed person or a sanctioned person

• determining the origin of funds or assets in a trade or business relationship, depending on the risk of legalization or terrorist financing

• finding out whether the client is acting in his own name

• conducting ongoing monitoring of the business relationship, including a review of specific trades executed during the business relationship to determine whether the trades are consistent with the client's knowledge of the client, his business profile and an overview of potential client risks, and ensuring documents, data or information are updated which the liable person has available about the client

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The liable person is obliged to perform basic care in relation to the client

• when concluding a business relationship

• in the case of an out-of-trade occasional trade of at least EUR 15 000 and in the case of an out-of-trade occasional trade in cash of at least EUR 10 000, regardless of whether the trade is carried out individually or as several consecutive transactions which are or may be be connected

• if there is a suspicion that the client is preparing or performing an unusual business operation, regardless of the value of the business

• in case of doubt about the veracity or completeness of previously obtained data necessary for the performance of care in relation to the client

• in the case of a payout of the balance of the canceled deposit

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The liable person shall determine the scope of care in relation to the client in proportion to the risk of legalization or terrorist financing. The obligated person is obliged to evaluate and take into account risk factors when assessing the risk of legalization or terrorist financing. The obligated person is obliged to prove during the inspection that the scope of care he provided in relation to the client is adequate depending on the risk of legalization or terrorist financing

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The client is obliged to provide the liable person with the information and documents that are necessary to perform care in relation to the client, or identification and verification of identification

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The liable person shall verify the validity and completeness of the identification data and information referred to in paragraph 1, depending on the risk of legalization or terrorist financing, also during the duration of the business relationship and shall record their changes.

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If the liable person finds out that the client does not act in his own name, he shall invite him to prove in the form of a binding written statement the name, surname, birth number or date of birth of the natural person or business name, registered office and identification number of the legal entity in which currency the business is conducted; the liable person shall proceed in the same way even if there are doubts as to whether the client is acting in his own name

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Store end-user benefits data

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End-user benefit data is archived permanently.

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Simplified care

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Simplified care is not provided as the clients are individuals.

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Exceptions to care in relation to the client

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They are not awarded

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Increased care 

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The liable person is obliged to exercise increased care if, on the basis of a risk assessment, one of the clients, one of the types of trade or a particular transaction presents a higher risk of legalization or terrorist financing. The obligated person shall always exercise increased care in the case of a cross-border correspondence relationship between a bank and a financial institution and a partner institution from a third country, in a trade or business relationship with a politically exposed person or a person established in a country designated as high risk by the European Commission.

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In the case of increased care, the liable person shall take other measures in addition to the basic care, depending on the risk of legalization or terrorist financing. Increased care in relation to the client shall be performed at least to the following extent:

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• in cases where the risk assessment shows that increased care is required and the client is not physically present for the purpose of identification and verification of identification

  • ​performing identification of the client through other documents, data or information and taking other measures to verify or confirm the submitted documents

  • requesting written confirmation from another bank, a foreign bank operating in the territory of a Member State or a financial institution operating in the territory of a Member State that it is its client

  • ensuring that the first payment is made through an account held in the client's name with a bank or foreign bank operating in the territory of a Member State, if the client has provided proof of the existence of such an account

  • a telephone conversation with a bank official in order to verify the existence of funds on the basis of a mandate

• In a business or business relationship with a politically exposed person

  • Identification of the origin of assets and the origin of funds used in a business relationship or business

  • continuous and detailed monitoring of the business relationship

• In a trade or business relationship with a person established in a country designated by the European Commission as

  • finding additional information about the client and the end user of the benefits

  • finding additional information about the purpose and intended nature of the business relationship or business

  • identification of the origin of assets and the origin of funds used in a business relationship or business

  • obtaining additional information from credible sources

  • continuous and detailed monitoring of the business relationship

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​Obligations relating to a politically exposed person pursuant to § 6 para. 1, the obligated person is obliged to apply for at least 12 months from the end of the performance of a significant public function; however, at the latest until the liable person, on the basis of a risk assessment pursuant to Section 20a, excludes for this client a risk specific to politically exposed persons

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9• Procedure for detecting an unusual business operation

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Detection of an unusual business operation

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The liable person is obliged to assess whether the planned or executed transaction is unusual and to pay special attention

• all complex transactions, unusually large transactions, all transactions of an unusual nature or transactions which do not have a clear economic purpose or a clear legal purpose, the liable person being obliged to examine the purpose of these transactions as much as possible

• any risk of legalization or terrorist financing that may arise from a type of trade, a particular trade or new technological practices in the conduct of transactions that may promote anonymity, and shall take appropriate measures if necessary to prevent their use for the purpose of legalization and terrorist financing;

 

The obligated person is obliged to make a written record of the trades, which he is obliged to have available at the inspection, the written record must contain information justifying the result of the assessment of the trade

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The obligated person is obliged to increase the degree and nature of monitoring the business relationship in order to determine whether the client suspects that the client is preparing or performing an unusual business operation

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Refusal to enter into a business relationship, termination of a business relationship or refusal to execute a business

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The liable person is obliged to refuse to enter into a business relationship, to terminate the business relationship or to refuse to execute a specific business if

• the liable person cannot perform care in relation to the client to the required extent

• the client refuses to prove on whose behalf he is acting

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Delay in an unusual business operation

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The liable entity is obliged to delay the unusual business operation until the reporting of the unusual business operation to the financial intelligence unit

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The liable entity is obliged to refrain from an unusual business operation if there is a risk that its execution may frustrate or make it significantly more difficult to seize the proceeds of crime or terrorist financing, or if the FIU so requests in writing, pending notification from the financial institution. the reporting agent to carry out the unusual business operation, but not more than 120 hours; after the expiry of this period, the liable person is obliged to delay the unusual business operation on the basis of the notification of the financial intelligence unit that he has handed over the matter to the law enforcement authorities, but for a maximum of another 72 hours. Saturday and non-working days are not counted until the delay in the unusual business operation. The liable entity shall immediately inform the financial intelligence unit of the delay of the unusual business operation

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The liable person shall not delay an unusual business operation if

• it cannot be delayed for operational or technical reasons;

• the delay could frustrate the processing of the unusual business operation, as previously reported by the FIU (financial intelligence unit).

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Reporting an unusual business operation

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The liable entity is obliged to report to the financial intelligence unit an unusual business operation or an attempt to perform it without undue delay. The obliged entity shall also notify the financial intelligence unit without undue delay of the refusal to carry out the required unusual business operation.

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The reporting obligation is fulfilled by submitting a report on an unusual business transaction in a way that ensures that the information contained therein remains confidential from an unauthorized person, namely

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• personally

• in writing

• in electronic form

• by telephone if the matter cannot be postponed; such a report must also be made in person, in writing or electronically within three days of receipt of the telephone report by the FIU.

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The report of an unusual business operation contains

• name, registered office or place of business and identification number of the liable person

• data obtained by identifying the persons concerned by the unusual business operation

• data on the unusual business operation, in particular the reason for the unusual situation, information on the essential circumstances of the business, the time course of events, account numbers, data on when they were established, who owns them and who has the right to dispose of them, photocopies of documents accounts established, identification of the persons authorized to handle the accounts, photocopies of concluded contracts and other related documents and information, as well as other information that may be related to the unusual business operation and are relevant for its further assessment

• data on third parties who have information about an unusual business operation

• name and surname of the person and telephone contact for this person

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An unusual business transaction must not contain information about an employee who has detected an unusual business operation

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The report is submitted to 

• NAKA Financial Intelligence Unit, mail: sjfpnoo@minv.sk

• copy of the National Bank of Slovakia, mail: stor@nbs.sk

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The liable entity is obliged to report to the financial intelligence unit, upon written request, additional information to the report on the unusual business operation and to provide related documents on the unusual business operation

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The notification of an unusual business operation is without prejudice to the obligation to report facts indicating the commission of a criminal offense.

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10• Method of data processing and storage

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For the purposes of caring for the client and for the purpose of detecting an unusual business operation, the liable person is entitled to detect, obtain, record, store, use and otherwise process personal data and other data, even without the consent of the persons concerned. In doing so, the liable person is entitled to obtain personal data necessary to achieve the purpose of processing by copying, scanning or otherwise recording official documents on an information carrier and to process birth numbers and other data and documents without the consent of the data subject.

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The liable person is obliged to keep the data permanently

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Obligations under the previous paragraphs also apply to the person who terminates the activity of the liable person

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Copies of documents must be made in such a way that the relevant data is legible and that it is possible to keep them, the image of the identified natural person in the identity document must be of such quality as to enable verification of the conformity of the identity of the identified person

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11• A method of ensuring the protection of an employee who detects unusual business operations

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The company's employees and management are obliged to maintain confidentiality about the reported fact and the subsequent measures of the financial police.

 

This obligation also applies to natural and legal persons who, for the subject of the obligation, resp. company, act on the basis of another contractual relationship. At the same time, this obligation does not expire upon termination of the employment relationship, similar employment relationship or other contractual relationship.

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Violation of the duty of confidentiality is considered a misdemeanor and is dealt with in accordance with the provisions of the law and other special laws, which is the law on misdemeanors no. 372/1990 Coll. and Criminal Code no. 300/2005 Coll.

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12• The method of monitoring compliance with the program and the obligations arising from this Act for the liable person

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Based on the valid schedule, the company organizes trainings, lectures and professional training on an ongoing basis. They include a written affidavit from each employee on full compliance with the program.

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The company's management carries out random, unplanned inspections aimed at complying with the principles of the Program of its own activities. The identified shortcomings are categorized according to importance and are subject to process improvement. Frequent violations by a particular employee can lead to termination of employment.

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Jankovce,   6.1.2022

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