This Finaura AML/KYC Policy (“Policy”) sets forth the rules and procedures
that the FINAURA OÜ, a company incorporated under the laws of Estonia
bearing the Registration Code 14696643, its subsidiaries and affiliated parties
(the ' Company') follows for detecting and preventing any financial crime.
This Policy is an integral part of the Company’s Terms of Use, which are at all
times available on the Company’s website.
The Company is strongly committed to preventing the use of its Services for
money laundering or any activity which facilitates money laundering, the
funding of terrorist or criminal activities, or any other illicit purposes.
The Company follows three internal procedures (the “Procedures”):
1) AML/KYC Procedure for exchanging a virtual currency against a fiat
2) AML/KYC Procedure for a virtual currency wallet service;
3) AML/KYC Procedure for exchanging a virtual currency against another
virtual currency.
The Procedures are administered by the Company’s director, the AML
Officer, and his team, together referred to as the Compliance Department.
The Compliance Department is tasked with monitoring compliance with the
relevant AML/KYC regulations and administrating the Procedures within the
AML/KYC Framework
The Company is licensed by the Estonian Financial Intelligence Unit (the
FIU”) to provide Services:
1) of exchanging a virtual currency against a fiat currency (License
2) virtual currency wallet service (License FRK001021).
The Company administers AML/KYC measures and Procedures, required by
the Estonian Money Laundering and Terrorist Financing Act (the “Act”) and
other legal guidelines given by the Estonian Minister of Finance for
businesses licenses to provide the above-mentioned Services.
Protection Measures
The Company has implemented protection measures, which protect the
Company from being involved and the Company’s Users from carrying out
any suspicious financial activity, by:
1) Performing KYC procedures on Users natural and legal persons and
their representatives;
2) Performing an enterprise-wide risk assessment to determine the risk
profile of the Company;
3) Implementing internal procedures, policies, and controls aimed at
mitigating risks of money laundering and terrorist financing;
4) Conducting AML/CTF staff training;
5) Conducting a periodic AML audit;
6) Maintaining and updating User information;
7) Reporting suspicious transactions to the relevant financial authority (the
KYC Measures
As part of the User Due Diligence, the Compliance Department shall:
1) Identify the User and/or its representative and verify submitted
information using reliable, independent sources, including using means of e-
2) Confirm the authenticity of documents and information provided by
3) Investigate Users, whose activities and/or documents have been
identified as suspicious or risky;
4) Request additional and/or updated documents and information from
Users when deemed necessary by the Company at any time;
5) Verify Users’ transactions on an on-going basis even if Users have been
identified in the past.
Please note that the Company shall have the right to request additional
and/or updated documents and/or information from any User at any time,
even if such User has been identified before. The Company may stop
providing Services to Users and/or report such Users to the FIU if they do not
provide the Company with requested documents and/or information.
Verification Levels & Requested Information
The Company shall implement different KYC Verification Levels, which are
available on the Company’s website. Emirex Verification Levels constitute an
integral part of this Policy.
Emirex Verification Levels perform the following functions:
1) Providing access to Services offered by the Company;
2) Increasing thresholds of Services, available to Users.
The level of verification, conducted on each User shall directly influence the
number of activities said User can perform on the Company’s website.
Information and documents requested from Users (both natural and legal
persons) are available on the Emirex Verification Levels page.
For the purposes of the Emirex Verification Levels, the following terms shall
have the following meaning:
1) Valid ID shall mean any of the following:
an identity card, digital identity card;
a driving license (which meets the requirements of section 4(1) of the
Identity Document Act); or
a residence permit;
2) Proof of Residence shall mean a utility bill, bank statement, credit card
statement, insurance, or tax statement issued within the last 3 months.
When making a transaction or a series of linked transactions for a value of
more than 15,000 EUR or equivalent in any fiat or virtual currency or at any
time requested by the Company, a User may be asked to provide a Proof of
Funds. A Proof of Funds shall mean any document that verified the source of
the User’s wealth, e.g. letter from a lawyer/agreement for gifts, sale
agreement for funds acquired from the sale of the property, tenancy
for rental income, copies of the company’s accounts, bank statements for
salary information, etc.
The Company may also send a User, for the purposes of the Emirex
Verification Levels or at any time decided by the Company, an KYC/AML
Questionnaire. A KYC/AML Questionnaire shall mean a series of questions
and/or a video-call with the Compliance Department, aimed to identify the
intent and the source of funds that are subject to User’s transactions and
activities and to rule out any illicit purpose.
Risk Factors & Risk Assessment
When carrying out initial and/or ongoing Procedures, the Company takes
into consideration the following risk factors:
Risk Factor
Risk Characteristic
1. Country of residence or nationality of the User is a
country with a risk of money laundering higher than
2. The User is a resident or a citizen of the low-tax or
tax-free country.
1. The User provides untruthful facts, including but not
limited to: discrepancies in provided ID documents,
fictitious person, a stolen identity, counterfeited ID
The document, post box home address, previous
financial crime record, terrorist record, wanted person,
2. The User performs suspicious, high-volume, and
unusual transactions;
3. The User is a politically-exposed person.
The Company may apply simplified or enhanced AML/KYC measured (as
defined in the Act), based on the results of the risk assessment.
List of countries the Company does not work with: Afghanistan, Albania,
Bahamas, Barbados, Botswana, Cambodia, Ghana, Iceland, Iran, Iraq, Jamaica,
Mauritius, Mongolia, Myanmar, Nicaragua, North Korea, Pakistan, Panama,
Syria, Sudan, Trinidad and Tobago, Uganda, Vanuatu, Yemen, Zimbabwe, the
Monitoring Requirements
The Company carries out ongoing monitoring of activities to prevent money
laundering, terrorism financing, and other illegal activities.
As part of the monitoring requirements, the Company shall:
1) Check transactions of its Users;
2) When needed, request documents to update/confirm information
gathered when applying KYC measures;
3) When needed, identify the User’s source of funds; 4) Pay additional
attention to suspicious, high-volume, and unusual transactions;
5) Pay additional attention to transactions made by Users from countries
with a risk of money laundering higher than usual.
Suspicious Activity Detection & Reporting
In an event that the Company suspects suspicious transactions, as identified
in its internal policies and procedures, based on the FIU Guidelines, it shall
conduct additional questioning regarding the User activity by the means of
the KYC/AML Questionnaire, and request any additional documents and/or
information that may be required.
In case the User has not provided document and/or information and
explanation about the suspicious transaction, a complete set of requested
documents, or has presented suspicious or unusual documents that the
Company cannot verify, and the Company reasonably suspects that User’s
activities may be connected to money laundering, terrorism financing, or
other illegal activities, the Company shall file a report on the FIU website
reporting the suspicious activity and reserves the right to suspend the User’s
account, suspected of such activities at its sole discretion.
Contacting the Compliance Department
If you have any questions about this Policy, the Procedures, or any other
AML/KYC-related matters, please contact the Compliance Department at