Customer Due Diligence policy AML / KYC NL

AML policy (Bank Secrecy Act (BSA) Anti Money Laundering (AML)

RevenYOU implements its AML policy with the help of professional verification market parties such as ComplyAdvantage. some components are:

- Connection to global sanctions and watch lists. Profiles of entities on global and national sanction lists (for example OFAC, HMT, UN and much more)

- Connection to additional information with real-time updates, for example photos, connections, media articles, source links, etc .
- Connection to thousands of government, regulatory, law enforcement, fitness and justice checklists
- Connection to deposited worldwide databases of PEPs in more than 200 countries continuously checked for updates- Connection to PEP classification in risk classes according to FATF guidelinesConnection to use PEP
-profiles expanded with connections, family members, close employees, photos and media articles In addition to collaboration with renowned market parties, RevenYOU has its own research department that actively and passively observes.

KYC (know your customer) policy

Identity verification in accordance with FATF and WWFT customer identification policies. Data is processed in accordance with GDPR. RevenYOU carries out its KYC with the help of professional verification market parties such as Mitek (NASDAQ: MITK).

Access to RevenYOU is done digitally via the app. Every user can only start after completing the digital ID, KYC and AML procedures. A client investigation is also always carried out at entities.

Policy Cryptocurrency exchanges

RevenYOU only works with cryptocurrency exchanges that score best in the field of KYC / AML integration and implementation. In this we follow our own research as well as research by third parties such as P.A.ID Strategies. The selection of cryptocurrency scholarships changes according to the results of the various studies.

Fourth and fifth anti-money laundering directives

RevenYOU conducts sharpened research regarding correspondent relationships. Among these relationships are the relationships between financial companies that have been entered into whereby services are provided by one institution to another, including services such as cash management, money transfers, transit accounts, currency exchange services and securities transactions. According to RevenYOU, this also includes platforms where cryptos are traded.

Activation with Cryptocurrencies

Activation via cryptocurrencies always leads to sharper customer due diligence. for example, information about family members and close business partners, sources of income, investigation of unfavorable reporting on the internet, investigation of business activities, etc., and verifying the documents for authenticity (for example, by comparing client documents with documents from the tax authorities, such as sales tax and income tax returns, copies of the external auditor, payslips from the employer, etc.). This investigation must then be done periodically. It is therefore a continuous sharpened client survey.

Legal opinion on the cryptocurrency

With regard to cryptocurrencies, RevenYOU only supports in-app purchases of pure cryptos. No tokens, ICOs and no anonymous coins such as Monero, Dash.

In addition, RevenYOU repels any involvement with Cryptocurrencies or money that may come from PEPs, sanction lists, or otherwise suspicious origin.

Cryptocurrency is a small (150 billion) market with high risk. Still we start here. Why? 1: Crypto’s lend excellent visibility for algorithm trading and 2: The crypto world has a large smart community of innovative and driven tech precursors. Algorithms achieve high returns on average.

Organization and implementation

RevenYOU has specifically set up its organization for, among other things, model risk management practices, client investigation, reporting, retention of supporting documents, internal control, compliance management and employee review. RevenYOU works with a person with final responsibility, a compliance function and an audit function. RevenYOU is also working on the preparation of a central contact point for the regulator. At RevenYOU, the policymaker is responsible for compliance with the Wwft. The task of the compliance officer is to supervise compliance with legislation and regulations and with the (internal) policy of the institution. In addition, the compliance officer makes any reports to the Financial Intelligence Unit (FIU). The person with the audit function checks compliance with legislation and regulations and the compliance officer.