KYC Policy

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.

SCOPE

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:

  • Compliance of AML Law 
  • Compliance of Regulatory Department’s requirements on KYC, CDD AML/CFT.
  • Compliance of host country legislations/ regulations on KYC, CDD AML/CFT& subsequent updates.
  • FATF Recommendations.
  • International Standards and guidelines, including Regulatory sanctions as applicable 

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: 

    Approval

    Rejection

    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

  1. Signature Is there
  2. Country is not a Restricted Country: 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 and Sint Maarten, Australia and its territories, United Kingdom of Great Britain, Northern Ireland and Cyprus. 
  3. Full Name matches user’s name 
  4.  Document does not expire in the next 3 months
  5. Owner is over 18 years of age 

 

2) Proof of Residence

  1. Bank Statement or Utility Bill
  2. Country is not a Restricted Country: 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 and Sint Maarten, Australia and its territories, United Kingdom of Great Britain, Northern Ireland and Cyprus. 
  3. Full Name matches client’s name and is same as in proof of ID. 
  4. Date of Issue: In the last 3 months 

 

3) Selfie with ID

  1. Holder is the same as in the ID document above 
  2. ID document is the same as in “1″. Make sure photo/ID number is the same 

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 

  1. There is a deposit limit per transaction
  2. Prior to any withdrawal there is a detailed algorithmic and manual check on the activity and balance of the user to see if the amount withdrawn is a result of proper activity in the platform. 

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.

 

 

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