Renverx

INTRODUCTION

BITVAULT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (trading as RENVERX) is a private company incorporated in the Republic of Poland with KRS 0001030740 and NIP 7252330396 having its registered address at UL. PIOTRKOWSKA 116 / 52, 90-006 ŁÓDŹ, (hereinafter referred to as “BITVAULT”, “RENVERX”, “Company”, “we”, “us”, “our”). RENVERX has entered into Polish Register of activities in the field of virtual currencies on 24th April 2023 with registration number RDWW-725.

PURPOSE

RENVERX takes extensive measures to implement adequate systems and follow strict controls to mitigate the risk and prevent facilitation of financial crime such as Money Laundering and Terrorism Financing. This AML & KYC Policy (hereinafter referred to as “Policy”) is designed to outline the AML & KYC practices used within the Company to identify its Customers, detect and report suspicious behaviors, maintain the outmost compliance and security standards pursuant to the relevant Law, Regulations, Directives.

DESCRIPTION OF MONEY LAUNDERING AND TERRORIST FINANCING

Money Laundering is a process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities. Money laundering enables criminals to maintain control over their illicit proceeds and ultimately to provide legitimate cover for the illegal source of the illicit proceeds. This means that proceeds

from criminal activities is converted into assets that gives it an appearance of legitimate money.
The Financing of Terrorism is defined as an offence established when a person “by means, directly or indirectly, unlawfully and willfully, provides or collects funds with the intention that they should be used or in the knowledge that they will be used in full or in part, in order to carry out a terrorist act or activity”. Terrorist financing is a unique form of financial crime. Unlike money laundering, which is finding dirty money that is trying to be hidden; terrorist financing is often clean money being used for lethal purposes.

The Company follows and applies the provisions of the law which reflect the Financial Action Task Force’s (hereinafter referred to as “FATF”) international standards to prevent, detect and combat money laundering and terrorist financing. There is no specific method of laundering money. Despite the variety of methods employed, the laundering process is accomplished in three basic stages which may comprise transactions by the launderers that could alert a financial institution to criminal activity:

Placement: is the physical deposit of criminal proceeds derived from illegal activity i.e., entering the collected cash into the financial circuits (payment in cash, exchange of bills, manual exchange, travelers’ checks, casino checks, etc.);
Layering:is the separation of criminal proceeds from their source by creating complex layers of financial transactions designed to disguise the audit trail and provide anonymity i.e., transfer between accounts, drawing of checks, foreign transactions etc.;
Integration: is the provision of apparent legitimacy to the proceeds of crime. If the layering process has succeeded, integration places the laundered proceeds back into the economy in such a way that they appear as normal (business) funds or other assets i.e., investing funds in lawful investments (stores, leisure activities, real estate, but also companies of all types, etc.).

RENVERX is committed to prevent facilitation of financial crime through its services and as such in the Company’s efforts we ensure to:

Get to know our Customers through request of legal documentation;
Identify and report any suspicious transactions through the appropriate channels;
Carry on an on-going monitoring of any reported suspicious activities;
Maintain all transaction records of Customers for a minimum of 5 years, following termination of the Agreement;
Ensure that all staff is sufficiently trained in the appropriate AML & KYC procedures as well as in what constitutes suspicious activity and to reporting such activity to the appropriate personnel;
Use all resources available, within the Company’s and other countries to ensure that all suspicious activities have been investigated;

Reserve a right to request all necessary verification documents from Customers;
Reserve aright to request additional or updated documentation, if so, deemed as necessary.

KNOW-YOUR-CUSTOMER (KYC) PROCEDURE

RENVERX is obligated to confirm and verify the identity of each Customer who wishes to use services of the Company. Every potential Customer of the Company creating a new account at our website renverx.com (hereinafter referred to as “Website”) is required to provide certain verification documents (which shall typically include but not limited to: Proof of Identity; Proof of Residence; Proof of the Client’s payment method). Required documents should be uploaded by Customer to the appropriate section within his/her user account. All uploaded documents should be clear, readable, without blur, without flash, without crossed out, painted over or erased information. No pictures or copies of pictures of documents are accepted, as well as pictures of monitor. If document contains handwritten signature, it should be clear enough to be compared with signature on person’s ID.

RENVERX identifies a Customer based on the following document types considered as Proof of Identity:

a valid passport, identity card;
a valid travel document issued in a foreign country;
a valid driving license.

Customer must upload front and back colored copy of a valid ID card/ passport / travel document/ driving license showing all 4 corners of the document, where the document must be valid for at least next six months. If the country of residence and country that issued ID/ passport / travel document/ driving license are different, and if residence is temporary, Customer needs to provide a copy of legal right to remain in the country of residence (e.g., visa, residence permit). Additionally, Customer is required to provide a Selfie holding his/her identification document.

Every Customer is required to provide documentation that verifies his/her place of residence. The document, Proof of Residence, is the official document issued within 3 months prior and addressed to the place of residence of the Customer. The document must contain the following attributes: full name and logo of issuing institution; full name of recipient of the document and address of recipient of the document (being the residence address of Customer). RENVERX identifies a Customer based on the following document types considered as Proof of Residence:

Bank statement;
Utility bill (water / electricity / gas / internet/ TV/ landline phone);
Letter or other document from state authorities (tax office, municipality).

Evidence of Source of Funds of private individuals is required for deposits over 10,000 EUR or equivalent. Depending on individual case we might request to provide evidence for deposits over 5,000 EUR or equivalent. As evidence of Source of Funds for private individuals we may accept Bank Statement or other document that shows the source of income and it is clear from the statement or document. Bank statement should show that client owns incoming or accumulated funds that will be used for deposit to RENVERX account. If funds are transferred from another account of the client, for that account bank statement should also be provided, and all requirements to clarity of origin of money apply to it.

RENVERX verifies the correctness of the provided data, using information originating from credible and independent sources.
RENVERX verifies email address and phone number of the Customer upon initial registration. In case there is a need to change verified email and/or phone number of the Customer, he/she is required to provide selfie with an ID card / passport/ driving license and a written application request for change of account details.

Upon depositing funds into RENVERX account, we ask to supply relevant proof of ultimate ownership of the funds used, e.g., masked picture of Credit Card showing cardholder name or Bank Statement showing the payment and details of the account owner. We reserve a right to request further supporting documentation depending on the specific case.

Additionally, Customers are required to support each inward and/or outward payment made to his/her RENVERX account with intention to use our services with relevant signed Declaration of Deposit and/or Withdrawal confirming their decision to use our services and acknowledgement of financial risks associated with virtual currencies.

KNOW-YOUR-BUSINESS (KYB) PROCEDURE

Upon registration of the corporate account, Customer is required to supply the following documentation for identification of legal person and collection of data prescribed by Money Laundering and Terrorist Financing Prevention Acts. The list of mandatory documentation typically includes but not limited to:

Extract from Business Registry (issued within last 3 months);
Certificate of Incorporation;
Certificate of Incumbency (issued within last 3 months;
Certificate of Good standing (issued within last 3 months;
Memorandum and Articles of Association or other document that sets up company’s structure, governance and shareholder’s control, defines kind of activities, structure of capital;
Recent corporate bank statement (for a period of last 3 months);
Certificate of Directors;
Certificate of Shareholders;
Confirmation of existence of other Authorised Signatories;
Corporate structure chart including information on shareholders and ultimate beneficiary owner;
Documents for identification and verification of each Director, Shareholder, UltimateBeneficialOwner,Authorised Signatory with Power of attorney if applicable (Proof of identity, Proof of residence);
Resume of Director/ Chief executive officer;
Business license (if applicable);
Taxpayerinformation;
Proof of domain ownership for corporate website of the Customer;
Internal decision (Order, Minutes of committee) that authorizes account opening with RENVERX.

If corporate customer was established less than 3 months before registration at our platform, the evidence of Source of Wealth and Source of Funds, used to form equity of the company should be provided. We may request additional information to explain business activities and purpose of possible business relationship.

All official documents issued in a foreign country must be legalized or confirmed with a certificate (an Apostille), i.e., an internationally recognized official certification of the authenticity of the document issued for use of an official document issued in one country in another country.

When signatories to the account change, the Company insures the identity of the new Signatories is verified. Periodic enquiries to establish whether there have been any changes to directors or shareholders or to the original nature of the business /activity are made as necessary.

Evidence of Source of funds for corporate clients is required in a form of corporate Bank statements or other relevant documents that shows the source of income).

ADDITIONAL DOCUMENTS

In case of enhanced KYC procedure required for specific Customer per decision of our Compliance team, or a suspicion of any kind of fraudulent activity, Customer has to complete an additional verification, which might include:

Second Proof of Identity;
Additional verification of Customer by personal video call;
Additional documents confirming Source of Funds and/or Source of Wealth;

The Company will accept a Customer only once he/she successfully complies with

KYC & KYB and due diligence procedures to ensure that a new relationship does not negatively affect reputation of the Company.
If Customer fails or refuses to submit within a reasonable timeframe set by the Company the required documents, data and information requested by the Company, we are entitled to terminate the business relationship and close Customer`s account. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If Customer denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship and close Customer`s account.

The Company takes no responsibility for any possible delays where the Customer`s verification documents are outstanding.
The Customer warrants and represents that at all times all the information provided to the Company shall be true, accurate, up to date and complete, and that the Client shall update the Company in writing via email (send to the Company from the Customer’s registered email address) upon any changes in regard to the information provided.

Customer agrees that the information collected and obtained by the Company may be used by the Company, its agents and service providers and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Customer hereby authorizes the above entities to conduct the above checks. The Company shall use all the information obtained from the Client in accordance with its Privacy Policy.

UPDATES TO AML & KYC POLICY

This AML & KYC Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at our sole discretion. Should any changes to this policy occur, the amended AML & KYC Policy will be available on our website.

ADDITIONAL INFORMATION

If you have any specific questions or concerns about AML & KYC procedures, please contact [email protected].

AML & KYC Policy

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