POLICY & PROCEDURES KNOW YOUR USER (KYC) USER DUE DILIGENCE (CDD) INTERNAL RISK ASSESSMENT.
SHAMBARA NV, a company limited by shares incorporated under the laws of the Curacao with registration number 154158 and with its registered address is Abraham de Veerstraat 9 Willemstad, Curacao (host country)
The objective of this policy is to ensure that the products and services of the SHAMBARA, and its subsidiaries and affiliates are not used to launder the proceeds of crime and that all users are aware of their obligations and the need to remain vigilant in the fight against money laundering/terrorist financing.
This policy is applicable to the Shambara’s operations including business of its affiliates and subsidiaries involved money, routed through Shambara.
Compliance with the Regulations of the host country on KYC, CDD AML/CFT will include:
USER DUE DILIGENCE & KNOW YOUR CUSTOMER
When logging in as user, in the process minimum documents/information must be provided at the time of opening of account. Further, any additional document/information may be obtained on case to case basis where considered necessary. The key point is that anonymous or obviously fictitious accounts should not be opened
When a user selects to make withdrawals inside the https://www.xigolo.com/home/ Platform, then it is compulsory for them to perform a full KYC process.
During this process, the user will have to input some basic details about themselves and then upload
1) A proof of ID (in some cases front and back depending on the doc)
2) A selfie of themselves holding the ID doc
3) A bank statement/Utility Bill
Once uploaded, information, the user will get a “Temporarily Approved” Status and the documents will now be on our side, and the “KYC Team” will have 24hrs to go over them and email the user about the outcome:
– More information needed – No change in Status
When the user is on “Temporarily Approved” Status then
– They can use the platform normally
– They cannot withdraw
– United States of America and its territories, France and its territories, Netherlands and its territories and countries that form the Kingdom of Netherlands including Bonaire, Sint Eustatius, Saba, Aruba, Curacao, Sint Maarten, Australia and its territories, United Kingdom of Great Britain and Norther Ireland and Cyprus.
Enhanced Due Diligence on KYC Process
1) Proof of ID
2) Proof of Residence
3) Selfie with ID
1) When the KYC process is unsuccessful then the reason is documented and a support ticket is created in the system. The ticket number along with an explanation is communicated back to the user.
2) Once all proper documents are in our possession then the account gets approved.
If it will be not possible to comply with the above requirements, account shall not be opened or business relationship shall be terminated, as the case may be and suspicious transaction report shall be submitted.
Risk assessment is must to be performed of all the existing and prospective users on the basis of information obtained regarding their identity, nature of income, source of funding, location etc. and based on the results of such assessment, categorize users among high risk, medium risk and low risk user.
If a user has been categorized as HIGH RISK*, it is necessary to have Enhanced Due Diligence (EDD) when dealing with such a user. Activities and transactions of HIGH-RISK users shall be monitored; and
1) If a user has not passed full KYC then they cannot withdraw
2) If a user has passed the KYC process successfully then
3) Under no circumstances may a user transfer funds directly to another user.
*Country or geographic risk factors
Country or geographical risk may arise because of the location of a user, the origin of a destination of transactions of the user, its location and the location of its geographical units. Country or geographical risk, combined with other risk categories, provides useful information on potential exposure to ML/TF. The factors that may indicate a high risk are as follow:
(a) Countries identified by credible sources, such as mutual evaluation or detailed assessment reports or published follow-up reports by international bodies such as the FATF, as not having adequate AML/CFT systems.
(b) Countries subject to sanctions, embargos or similar measures issued by, for example, the United Nations.
(d) Countries identified by credible sources as having significant levels of corruption or other criminal activity countries or geographic areas identified by credible sources as providing funding or support for terrorist activities, or that have designated terrorist organizations operating within their country.
(f) Jurisdictions in which the user and beneficial owner are based;
(g) Jurisdictions that are the user’s and beneficial owner’s main places of business.