Anti-Money Laundering/Know Your Customer (AML/KYC) Disclosure
Last Modified: June 24, 2022
By agreeing to the Terms and Conditions, Members also acknowledge that the Company has implemented a risk-based AML/KYC program summarized hereafter. All capitalized terms not defined herein shall have the meaning ascribed to them in the Terms and Conditions, as applicable.
The Company protects itself and fights against money laundering, terrorist financing or OFAC sanctioned subjects and activities by establishing the following:
- A system of internal controls designed to assure ongoing AML and OFAC compliance;
- Periodic Independent testing of AML compliance by the Company, its vendors or business partners;
- Designation of a BSA/Sanction Compliance Officer for managing AML Compliance; and
- Periodic AML training for employees.
The Company has established a set of AML/KYC policies and procedures to define and guide the operations of internal controls for the purpose of ensuring that its operations comply with relevant AML requirements and risk mitigation measures, based on the company’s risk appetite and profile.
The Company’s AML program will be subject to independent testing through a periodic, independent AML audit.
BSA OFFICER AND CHIEF COMPLIANCE OFFICER
The Company has appointed a designated officer (BSA Officer) to be responsible for the management, coordination and monitoring of compliance with the Company’s internal controls. The BSA Officer reports to the Chief Executive Officer(CEO) based on governance structure.
Employees or contractors of the Company are required to receive AML training periodically or based on demands. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.
CUSTOMER IDENTIFICATION PROGRAM AND NOTICE
Each Member that opens a new account on the Company’s platform will be directed to complete the procedures established for the Customer Identification Program (“CIP”) and KYC. It is the Company’s policy to ensure that each Member who uses the Company’s platform has been reasonably identified.
Important Information About Procedures for Opening a New Account
To help the Government fight the funding of terrorism and money laundering activities, we obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.
If you are an entity customer or prospective customer, we will ask for your registration document, incorporation document, license document or similar evidence that establishes your entity identity. We will also ask for your controller and ultimate beneficial owners’ identification information.
ACCOUNT OPENING PROCEDURES
The following additional steps will be taken during account opening process,: (i) cross-check the names of users against Government Lists such as the OFAC Specially Designated Nationals list; (ii) require users to verify and validate their identity and identification documents presented at onboarding; and (iii) not permit any activity on platform with incomplete account opening information.
We do not accept US Members as Company Customers/Members at this time. US companies and persons who identify a US address or US nationality when attempting to create an account will not be allowed to onboard as a Member. If a US person or company obtains HUSD outside of the Company, that person or company will not be allowed to redeem HUSD for U.S. dollars from the Company, as they will not have an account with the Company.
- Legal name
- Date of birth
- Residential address
- Identification number
- Acceptable and valid government-issued identification document (e.g., drivers license, passport, national identification card)
- Institution’s Registered name
- Doing Business As name (DBA)
- The address of the institution’s principal place of business and, if different, the institution’s mailing/registered address
- Identification number of the institution (e.g., employer identification number)
- Name of institution’s representative/user for the account
- For institutions, the Company will collect the identifying information with respect to each beneficial owner and will use risk-based procedures to verify the identity of such beneficial owners, including:
- Acceptable and valid government-issued identification document (e.g., drivers license, passport, national identification card) for each beneficial owner; and
- Proof of residency (e.g., utility bills, government issued correspondence, documentation issued by recognized financial institutions).
- Customer due diligence procedures will include additional information regarding the institution including but not limited to the following:
- A description of the institution’s business, including products and services, main Member types, and geographies served;
- Purpose of account; and
- Source of funds.
Use of HUSD for Illegal Activity Prohibited
We may freeze, temporarily or permanently, your use of, and access to HUSD or your ability to redeem HUSD for US dollars, with or without advance notice, if we are required to do so by law, including by court order or other legal process.
Your HUSD may be subject to seizure or forfeiture by law enforcement, and we will comply with legal process in respect thereof.
If we determine after investigation that HUSD has been used, or is being used, for illegal (or sanctioned) activity, we may not permit you to redeem HUSD for US dollars from Stable Universal, and, if presented for redemption, such HUSD may be forfeited.
Any HUSD that is subject to freeze, seizure, forfeiture or similar limitation on its use imposed by law may become wholly and permanently unrecoverable and unusable, and in appropriate circumstances, may be destroyed.
This applies to all holders of HUSD, regardless of whether the holder is a Member (as such term is defined in the Stable Universal Terms and Conditions) of Stable Universal.
By using HUSD, you agree that we may take the actions set forth above, including those specified in Terms and Conditions, and that we will not be liable to you therefore.
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