7
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