INTERNAL POLICIES OF AML VERIFICATION

Last update. December 2022

This policy is part of our general terms and conditions, concerning the prevention against identity theft, financing of terrorism, organized crime, asset laundering and money laundering in force in the countries of operation of our platform, so that both guarantee the deconfiguration of illegal activities and the achievement of funds through illegitimate means.

Safesolf complies with the standards required by international regulations in this regard, so that security and compliance with the law prevail in our transactions, therefore our accessibility requirements for Distributors are rigorous, maintaining the necessary regulatory compliance to guarantee efficient security in such operations. Distributors are responsible for abiding by applicable laws regarding the legal use of the Platform in their local jurisdiction, as well as being in compliance with other laws and regulations applicable to them by connection.

These policies and any terms incorporated herein, apply to the Distributor, whether a natural person or legal entity, the use of the Services, including those offered in https://encriptados.io, the technology and any platform integrated into it and any related application associated with it, which are operated and maintained by SAFESOLF INTERNACIONAL S.A.S. or a third party, are subject to these conditions. For Colombia, the procedures for the prevention and risk control of Money Laundering and Financing of Terrorism are contained in our complete and updated SARLAFT Manual (Risk Management System for Money Laundering and Terrorist Financing).

COMPLIANCE AND DECLARATIONS

This policy constitutes a binding and comprehensive agreement between SAFESOLF INTERNACIONAL S.A.S. and the Distributor, for which, as soon as you visit the website and use the services, you confirm that you have read and accepted these Terms of Use and the present policies in their entirety before completing the registration procedure, thus it is adopted and accepts the terms of use and data processing policies available on our website.

The Distributor accepts that the current Terms may be updated by SAFESOLF INTERNACIONAL S.A.S. At any time. If the Distributor does not read and accept these terms in their entirety, the Distributor must not use or continue to use the Services. We reserve the right to amend or modify these policies, adapting them to the continuous legislative changes, which will always be in force on our website home page.

The Distributor understands and declares to know that our Services give the possibility of marketing the products and services available on the website www.encriptados.io, in accordance with what is established in the Contract signed by the parties; For this reason, said activity implies the need to guarantee our security filters so that our privacy policies are fully complied with AML VERIFICACIÓN (anti-money laundering), KYC (know your customer), CIP.

Distributors are responsible for verifying whether they are allowed to carry out the transactions of the contractual object under the competent laws in their territory. The Platform exempts itself from any responsibility in the event of any illegality occurring or foreseeing in the transactions of the Distributors or their dependents, business partners, among others, SAFESOLF INTERNACIONAL S.A.S. is at the discretion of verifying the transactions and come to verify the illegality as the case may be and take actions in accordance with the competent laws and regulations, in the following cases:

• We reasonably suspect that this Policy has been or may be violated and fraud has had place on our identity verification processes.
• We detected that the Distributor uses multiple accounts, which is prohibited in our current policies.
• We consider the protection of other Distributors necessary, therefore the services will be denied.
• We determine that the Distributor is using our Platform in a way that negatively affects or prevents other Distributors from taking advantage of our Services.

The Distributor, with access to the platform, accepts our discretionary decision to take measures that range from limitation, suspension and closure of the account, if any previously exposed circumstances are noticed, due to the need to apply security and verification protocols, withdrawing said measures if the circumstances that caused them are corrected.

Such measures will persist if:

1. The risk control system detects irregularities, and the Distributors involved explicitly refuse to collaborate with the Platform, or do not actively do so, to carry out the subsequent verification concerning money laundering and terrorist financing
2. The Distributors Accounts are detected as suspected fraud (or attempted fraud), withdrawals to high-risk platforms (such as unlicensed cryptocurrency dealer platforms, online gambling platforms, platforms suspected of being involved in money laundering or fraud, or other high risk entities) or other high risk asset transfers.
3. An Account is not being used by the registered Distributor, or is being used illegally to purchase digital assets for third parties. The Distributor is found to be selling, lending or renting their Account to third parties, or illegally purchasing digital assets for third parties.
4. Reception or introduction of digital assets or funds from illegal sources. The Distributors know or can reasonably infer from their common sense that funds received from other Platforms are of an illegal origin or nature, and still allow their flow to the Accounts of other Distributors on the Platform.
5. Distributors identified as involved in money laundering: The risk control system detects, or is confirmed by risk control personnel, that a Distributor is directly participating or assisting in money laundering activities.
6. Freeze of the Account authorized by court order: an Account has been frozen at the request of a judicial institution.
7. Investigation for legal compliance: Distributors are requested through a judicial institution to retrieve information from their Account on the Platform, for judicial investigation and consulting purposes, among others.

SAFETY CHECKS

In order to use the functionalities of the platform in SAFESOLF INTERNACIONAL S.A.S. , the Distributor must pass the following registration processes, and identity verification, in order to collect the personal information of the Distributor, data such as their full name, place of residence, date of birth and address, so that they are compared with the official documentation provided by the Distributor, verification of the proof of real residence and the identity of the Distributor in competent official databases, in order of residence and jurisdiction factors.

KYC VERIFICATION STEPS

1. Identify Distributors.

This process begins from the supply of the Distributor’s data, whether he is a natural, legal or moral person; collecting your personally identifiable information, full name, place of residence, date of birth and address:

• Distributor Name.

Email. Seniority and existence of said account is verified as well as a behavioral risk assessment based on the email address

1. Phone number. 

The existence of the number is verified by sending an SMS message with verification code to the owner Distributor.

• Official Identity Verification. The Distributor must deliver a constitutive official identity document of the country where they are located (Front and Back), among which national identifications, driver’s licenses, tax cards, voter ID, Passports and others are accepted.

The uploaded document must contain at least the following data:

1. Full name
2. Expedition date
3. Issuing authority
4. Date of birth. (for a natural person), for verifications of legal age.
5. Date of Expiry.

The upload of said document(s) in image, is necessary to execute specific verifications to determine if the document is valid, belongs to the Distributor and is reliable, also if said document was subject to alterations or manipulation, or the opening of other accounts on the platform with the identity document, which would effectively make the opening of the Distributor’s account unfeasible.

1. Quotation with government databases to verify the report in said databases and proof of the existence of said document, for which SAFESOLF INTERNACIONAL S.A.S. reserves the right to request an additional document that effectively verifies the person’s proof of existence.
2. This verification is carried out with specialized verification platforms, redirecting the data to said platform, in such a way that it offers extreme security in said verification.

SAFESOLF INTERNACIONAL S.A.S. reserves the right to request a video or any other additional documents that allow full certainty of said identity.

1. Verification with biometric data, only for natural or physical persons, so that the physical characteristics of the images delivered by the Distributor match, in correspondence with the official identity document, also verifying if the Distributor who interacts with the application is the intended and authorized person.

Other features of biometric verification include:

1. The video or selfie submitted by the Distributor shows that it is a real human being.
2. It is verified that the photo or video matches the identification document uploaded as part of the document verification block.
3. The Distributor’s video or selfie is verified to match the government database specified as part of the Government Verification block.
4. Age accessory control. It is verified that their physical characteristics meet the age requirements.
5. Verification of residence address, the existence of a real address and proof of the existence of said address are verified through GPS location, and validation of postal codes.

In the case of a legal or moral person, the review of the adoption of AML policies or risk management in asset laundering and money laundering is also estimated in order to the competence and jurisdiction of the Distributor, under platforms attached to SAFESOLF INTERNACIONAL S.A.S. .

The anti-money laundering watch lists (AML) are issued by national and international organizations such as the FBI, Interpol and the United Nations, in which the names of people and companies that have participated in criminal activities rest, for this reason, our AML verification compares the Distributor against more than a thousand international watch lists, sanctions lists and lists of politically exposed persons (PEPs).

If a Distributor is found on any list, verification will be subject to a second review, either at the AU Government Department of Foreign Affairs and Trade, Inter-American Development Bank, GB Consolidated Target List Her Majesty’s Treasury Sanctions List – Persons of Interest Swiss SECO Sanctions, UK Bank of England Sanctions List, UN Consolidated Sanctions, US Bureau of Industry and Security Denied Persons in US US OFAC PEP

CIA World Leaders, Council of Europe Parliamentary Assembly, EU MPs, Colombian SARLAFT, US DEA, US FBI, INTERPOL Red and Black Notices, US Marshalls Service.

SUBSEQUENT PROCEDURE AND ELIGIBILITY

After said process, internally, the internal verification procedures were carried out, in order to give rise to the effective creation of a Distributor account accessible after the registration process and through the Services of the SAFESOLF INTERNACIONAL S.A.S. platform. Therefore, it is clear that you must go through all the AML/KYC procedures without inconvenience, which may be applied to you in accordance with our internal AML/KYC policies. As part of said procedures, SAFESOLF INTERNACIONAL S.A.S. reserves the right to request additional information and documents, which are intended, among others, to identify our Distributor and prove the origin of the funds;

The Distributor must manage and maintain only one account of SAFESOLF INTERNACIONAL S.A.S. , for which it is obliged to:

1. Change the password from the automatically generated one to a strong password.
2. Provide an exact email. Access to the services provided by SAFESOLF INTERNACIONAL S.A.S. is not allowed without email verification;
3. Maintain the security of your Account and notify us immediately if you discover any suspicious activity related to your account;
4. Assume responsibility for all activities that occur in your SAFESOLF INTERNACIONAL S.A.S. Account.

We strive to protect our Distributors from fraud and fraudulent activities in the field of crypto assets. Some crypto assets may be intended for illegal seizure of property, or construed as fraud, scam, or any other activity recognized by law as illegal and/or not in compliance with legal requirements. SAFESOLF INTERNACIONAL S.A.S. cooperates with law enforcement agencies and other competent authorities to determine and disclose such crypto assets. We reserve the right to prohibit and discontinue any Exchange through our Services with such crypto assets at our sole discretion, without prior notice and without publishing the reason for such decision, provided that we are aware of it. Upon entering the platform, the Distributor INDEMNIFIES AND RELEASES SAFESOLF INTERNACIONAL S.A.S. LIABILITY WISE AGAINST ANY CLAIM, DEMAND AND DAMAGES, WHETHER DIRECT, INDIRECT, CONSEQUENTIAL OR SPECIAL for said security reason and verification in these policies.