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KYC / AML / CFT Policy

Know Your Customer (KYC), Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) is the process of a company verifying the identity of its clients, assessing potential risks of illegal intentions for the business relationship, and finally making an effort to prevent, detect, and report suspicious activities.

KYC / AML / CFT policies are not only a means of combating fraud, but also provide Idoneus with a competitive advantage; this is because more transparency and security lead to more trust by our clients, and thus a higher acceptance rate of IDON and cryptocurrency in general.

Idoneus is committed to full compliance with all applicable laws and regulations regarding money laundering and the financing of terrorism. Every officer, director, employee and associated person of Idoneus is responsible for assisting in the company’s efforts to detect, deter and prevent money laundering and other activities intended to facilitate the funding of terrorism or criminal activities through its business.

Idoneus International AG (Idoneus) is a member of the Verein zur Qualitätssicherung von Finanzdienstleistungen (“VQF”). The VQF is the leading, largest, officially recognised self-regulatory organisation (hereinafter: “SRO”) in Switzerland, pursuant to the Federal Act of 10 October 1997 on the combating of money laundering and the prevention of the financing of terrorism in the financial sector. Association under the terms of Art. 60 et seq. of the Swiss Civil Code (SCC), recorded in the Commercial Register of the Canton of Zug and enjoying the official recognition of the Federal Financial Market Supervisory Authority (FINMA) as an SRO pursuant to Art. 24 AMLA. The VQF SRO exercises legally prescribed supervisory functions towards its members.

As a member of VQF, Idoneus is subject to provisions on Anti Money Laundering (AML) under the laws of Switzerland, which are in accordance with the FATF recommendations. Switzerland is a member country of the Financial Action Task Force FATF).

The following provisions form an integral part of Idoneus’ Terms of Use and Privacy Policy, and must be read in connection with them.

1. Idoneus does not enter into business relationships or transactions with clients and partners having the following characteristics:

  • Country restrictions: sanctioned high-risk countries.
  • Country restrictions: countries with full bans on crypto.
  • PEP restrictions: active government members of high-risk countries.
  • Activity restrictions: arms and armaments trade, private military, casino and lottery business, erotic trade, international trade in exotic animals.
  • Assets: sourcing of diamonds, gemstones, precious metals, etc that are not compliant with United Nations resolutions for conflict-free sourcing (such as the Kimberley Process).

2. Idoneus, as a supervised financial intermediary, complies with Federal Act on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act of 10 October 1997, CC 955.0, « AMLA »). Preventing and fighting money laundering is a central element of the legislative framework put in place by regulatory authorities in developed countries. The Anti-Money Laundering Act is designed to prohibit the movement of funds from criminal activities and to eradicate the availability of financing for terrorist activities.

3. Idoneus undertakes to comply with the law and to combat all forms of money laundering, in particular through the service provided by Idoneus. Idoneus strictly complies with its duties of due diligence, by taking all necessary measures, including the following:

  • Verification of the identity of the client (Art. 3 AMLA);
  • Verification of the identity of the beneficial owner (Art. 4 AMLA);
  • Repetition of the verification of the identity of the client or the verification  of the identity of the beneficial owner (Art. 5 AMLA);
  • Special duties of due diligence and clarification of the economic background and the purpose of a transaction or of a business relationship (Art. 6 AMLA);
  • Duty to keep and retain records for a minimum of ten years (Art. 7 AMLA).

4. Idoneus is required by law, when establishing business relationships, to verify the identity of the other party on the basis of duly certified and valid supporting documents. When the contracting partner is a legal person, Idoneus must gather information on the powers to legally bind and represent that legal person and verify the identity of the persons establishing the business relationship on behalf of the legal person.

5. The client must provide Idoneus, spontaneously or upon request, with any information and document, allowing to identify and clarify the identity of the client, the economic beneficiary (s) and the origin of the funds, at the beginning of the relationship or when conducting the repetition of the verification in compliance with the duties of Idoneus.

6. Idoneus may require any information and / or supporting documentation on the object and purpose of the operation that the client wishes to conclude with Idoneus, in particular on the origin and destination of the funds committed. The extent of the information to be collected will depend on the nature of the transaction or the risk represented by the client.

7. Idoneus may require additional supporting documents, in particular to prove the reality and transparency of the commercial operations justifying the exchange transactions.

8. Idoneus is subject to the following duties in the event of any suspicion of money laundering:

  • Duty to report and inform the competent authorities in the event of suspicious transactions or suspicions of money laundering (Art. 9 AMLA);
  • Freezing of assets (Art. 10 AMLA).

9. Idoneus reserves the right to decline to enter into a relationship with a potential client and / or to refuse to execute a transaction at any stage of the relationship with a client, if the information provided by the potential client or existing client is found to be intentionally false or incomplete or if Idoneus suspects any link to illegal activities.

10. To the extent permitted by law, Idoneus has the right to take all the necessary measures to remove any suspicion and proceed, if necessary, to any communication to the competent authorities, as well as to freeze the assets concerned.

11. The collection of information on the client and the transactions he / she wishes to carry out is crucial in order for Idoneus to comply with the applicable legislation. The collection of information by Idoneus is described in its Privacy Policy.

12. To fulfill its regulatory duties, Idoneus is required to disclose KYC data to the regulatory authorities on its clients and transactions.

13. Idoneus reserves the right to use the services of a third party to confirm the information gathered. The client undertakes to inform Idoneus of any changes subsequent to the opening of the relationship. At this time, Idoneus utilizes the services provided by KYC Spider AG (Switzerland) and Sum and Substance Ltd (UK).

14. Due to the applicable legislation, the information collected must be kept by Idoneus for a period of ten years after the termination of the business relationship or after the execution of a transaction (Art. 7 para. 3 AMLA).

15. By using Idoneus’s services for inappropriate purposes, the client may be exposed to criminal prosecution.

16. Idoneus has implemented the following procedures:

  • Gathering basic KYC data and documentation about potential clients (such as: name, address, nationality, date of birth, copy of passport, etc). This is for legal and natural entities. Basic KYC check includes:
    • Establishment of the beneficial owner’s identity
    • Establishment of the controlling person’s identity
    • Collection of information regarding the clients’ business activities
    • Verification of origin-of-funds
  • Usage of national and international sources to enrich the data in the KYC records:
    • Sanctions lists, terror lists, wanted persons in relevant jurisdictions (UN, SECO, EU, OFAC and other sources)
    • PEP lists from different sources
    • Additional Compliance Relevant Information (CRIME)
    • Publicly accessible negative press and company information
  • Video Identification and Online Identification: to identify an entity in accordance with Circular 2016/07 of the Swiss Financial Market Supervisory Authority FINMA.
  • Enhanced Due Diligence (EDD): an in-depth examination of new as well as existing clients. This involves determining whether there is an increased risk of money laundering, corruption, bribery, arms trafficking or terrorist financing.
  • Transaction monitoring and compliance with the Travel Rule.
  • Establishment and maintenance of risk-based systems and procedures to monitor on-going client activity.
  • Report suspicious activities to FINMA.
  • Record retention procedures.
  • Continuous training of management and staff.
  • Annual AMLA audit.

17. Idoneus verifies the wallets from which clients remit any cryptocurrencies; verification means obtaining some evidence which confirms the wallet: (i) is not related to terrorist financing; (ii) is not related to the darknet market; (iii) does not belong to mixers; or (iv) does not relate to a sanctioned country. The verification of the wallet consists of the company verifying the information received against documents, data or information obtained from a reliable and independent source.

18. Clients of Idoneus are obliged to cooperate with the required KYC, AML and CFT procedures. Failure to comply will lead to the discontinuation of the business relationship.

19. If you have questions or comments about these Policies, please contact us using the information below:

Idoneus International AG
Baarerstrasse 12
6300 Zug
Switzerland

Email: compliance@idoneus.io

Last revised date: 17.01.2024