Changeangel is committed to the highest standards of the Anti-Money Laundering (AML) compliance and Anti-Terrorist Financing and requires the management, and employees to follow the named standards.
This Policy outlines the minimum general unified standards of internal AML control which would be adhered to by the company in order to mitigate the legal, regulatory, reputational, operational, and as a consequence financial risk.
The objective of the guidelines is to prevent the company from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities. The Policy also enables the company to know / understand status of its Investors / Users and their financial dealings better, to manage risks including reputation.
Changeangel adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company's services by criminals, with the aim of money laundering, terrorist financing or other criminal activity.
For this purpose, a clear policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was implemented by the company, which correlates with the policies of Changeangel’s partner exchanges.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing is an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.
The process of money laundering can be divided into three sequential stages:
Placement. At this stage funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing.
Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.
Integration. Funds get back into circulation as legitimate to purchase goods and services.
In response to the scale and effect of money laundering, the United States of America and the European Union has passed Laws and Directives designed to combat money laundering and terrorism. These Acts, together with other regulations, rules and industry guidance, form the cornerstone of our AML/CTF obligations and outline the offenses and penalties for failing to comply.
Whilst Changeangel provides Cryptocurrency services, it is currently unregulated and does not fall within the scope of the AML/KYC-AML/CTF obligations, our management have implemented basic systems and procedures that meet the standards set forth by the United States of America and the European Union. This decision reflects the management’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
ANTI-MONEY LAUNDERING POLICY
Changeangel is a swap aggregator, which means that the services are provided by multiple exchange service providers, and to that purpose, Changeangel aggregates the pricing and routes transactions directly to those exchanges. Changeangel is affiliate partners with those exchanges, and, as a result, we implement a limited AML/KYC policy, complementary to the AML/KYC policies of the partner exchanges. This means that the User may have to fulfill further AML/KYC procedures pertaining to such partner exchanges, on a case by case basis. These other exchange service adhere to strict AML/KYC guidelines in accordance with their local laws and require AML/KYC checks based on transactions and monitoring, if deemed necessary, based on their own policies and procedures.
Each partner exchange has developed and implemented their own risk-based anti-money laundering program, which may be comprising of:
- Written Anti-Money Laundering Policies
- Customer Identification Procedures
- Anti-Fraud Procedures
- Record-Keeping Requirements
- Customer Risk Assessment Procedures
- Sanction Lists Procedures
- Employees Training Procedures
- On-going Customers’ activity procedures
These affiliate partner exchanges, along with Changeangel, may utilize systems that monitor transactions against illegal activity. If a transaction triggers AML/KYC verification, we need to be able to readily contact you. If those affiliate swap exchange partners require KYC information to satisfy their procedures, we will inform you and provide you details where to send information.
In the event an AML/KYC verification is triggered, we would ask that you provide the third-party affiliate exchange service, directly a;
- Copy of government issued ID;
- Passport or national ID;
- Explanation and proof of funds;
- Any other applicable documents;
We can provide a list of those affiliate exchange partners upon request.
The Changeangel AML/KYC Policy, in cooperation with the partner exchanges, is designed to prevent money laundering by meeting the worldwide standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
- Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
- Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
- Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
- Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- Maintaining appropriate records for the minimum prescribed periods;
- Providing training for and raising awareness among all relevant employees.
The Users may have to undertake, upon request, a verification procedure. Changeangel may exercise its right, before it starts any cooperation with the User, or during the cooperation, to ensure that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to Users, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.
Changeangel will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Changeangel reserves the right to investigate certain Users who have been determined to be risky or suspicious.
Changeangel reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Changeangel reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
Once the User’s identity has been verified, Changeangel is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
During the process of registration, each User provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and city code. A User sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:
- a high-resolution copy of the first page of local or international passport, where the photo and the signature are clearly seen, or a copy of driver's license with the same requirements. The indicated documents must be valid at least 6 months from the filing date.
- a high-resolution copy of a receipt of utility services payment or bank statement, containing the full User's name and the actual place of residence. These documents should not be older than 3 months from the date of filing.
Potentially Required Information
Changeangel or its partner exchanges may request, on a case by case basis, some or all of the following information:
- Full name;
- Date of birth;
- A unique photo of them holding their government-issued photo ID.
Verification of identity may be required by obtaining a high-resolution, non-expired copy of the User’s government-issued ID (passport, national identity card, or a driver’s license). The submitted imaged requirements include:
- Full color image. Black and white, watermarked, etc. may not be accepted;
- Legible. All information on the ID must be completely clear and readable;
- Background. The edges of the ID document must be clearly visible on a contrasting background.
Proof of residence
Verification of residence may be required by obtaining a copy of an acceptable address proof document issued in the 3 months prior to establishing an account. The document must carry the User’s name and address.
A valid proof of residence document can be:
- bank statement;
- debit or credit card statement;
- utility bill (water, electricity, gas, internet, phone);
- payroll statement or official salary document from employer;
- insurance statement;
- tax document; or
- residence certificate.
Proof of residence documents must contain the User’s name, address, and be dated less than 3 months ago.
Unique photo of User
Changeangel reserves the right for further verification, if deemed necessary, or if required by the partner exchanges, on a case by case basis, and may request from Users to submit a unique photo of themselves holding their government-issued ID as well as a unique handwritten note. In the photo, the User must be visibly smiling. This allows Changeangel to easily prove that the User’s picture was not stolen or photoshopped, and is being used exclusively for Changeangel.
The ID the User holds in their hand:
- must be the same government-issued ID the User submitted previously; and
- must be fully clear and readable.
The note the User holds in their hand:
- must be handwritten (not typed);
- must be in English;
- must contain today's date;
- must contain the sentence: For trading at wcex.com only; and
- must contain the User’s signature.
Based on the risk, and to the extent reasonable and practicable, we ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about Users.
We or our partner exchanges may decide to use the following non-documentary methods of verifying identity:
- Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database or other source;
- Checking references with other financial institutions;
- Analyzing whether there is logical consistency between the identifying information provided, such as the Users’ name, street address, postal code, and date of birth;
- Utilizing complex device identification (such as “digital fingerprints” or IP geolocation checks); and
- Obtaining a notarized or certified true copy of an individual’s birth certificate or government-issued ID for valid identification.
In case the applicant company is listed on a recognized or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required. In case the company is unquoted and none of the principal directors or shareholders already has an account with Changeangel, the official provides the following documents:
- a high-resolution copy of the certificate of incorporation/certificate;
- an extract from the Commercial Register, or equivalent document, evidencing the registration of corporate acts and amendments;
- names and addresses of all officers, directors and beneficial owners of the corporate entity;
- a high-resolution copy of Memorandum and Articles of Association or equivalent documents duly recorded with the competent registry;
- evidence of the company’s registered address and the list of shareholders and directors;
- description and nature of business (including the date of commencement of the business, products or services provided; and the location of principal business).
This procedure is performed to establish the identity of the User and to help Changeangel know / understand the Users and their financial dealings to be able to provide the best services of online trading.
MONITORING OF USER ACTIVITY
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do), but this is an attribute of the partner exchanges. Therefore, Changeangel only keeps records of the transaction by way of amount date IP receive address and send to addresses. The partner exchanges have the right to perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Regular check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
- Case and document management.
A suspicious transaction is known as a transaction that is inconsistent with the User's legitimate business or the usual User's transaction history known from User activity monitoring. Changeangel has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the company's services by criminals.
The company reserves the right to suspend any User's operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.
We make sure that AML records are maintained properly.
We document our verification, including all identifying information provided by a User, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We keep records containing a description of any document that we relied on to verify a User’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we retain documents that describe the methods and the results of any measures we took to verify the identity of a User.
We also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We retain records of all identification information for seven years after the account has been closed, or as long as reasonably necessary to comply with applicable regulations; we retain records made about verification of the User's identity for seven years after the record is made, or as long as reasonably necessary to comply with applicable regulations.
All new employees receive anti-money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML training annually. Participation in additional targeted training programs is required for all employees with day-to-day AML and KYC responsibilities.
Our training includes, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual User activity or other red flags (3) what employees' roles are in Changeangel’s compliance efforts and how to perform them; (4) Changeangel’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance.
Our operations are regularly reviewed to check whether certain employees require specialized additional training. Written procedures are updated to reflect any such changes.
Changeangel is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Changeangel will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.