Policy for the fulfilment of requirements in the fight against money laundering and terrorism financing

The purpose of this Policy in the fight against money laundering and terrorism financing (hereinafter referred to as Policy) is to prevent any activity related to money laundering and terrorism financing as well as the opportunity to use one’s own products and services for the purposes of money laundering.

“Money laundering (legalization of income obtained in an illegal way)” means transfer or assignment of property while knowing that such property has been obtained from an illegal activity or from participation in such activity, for the purpose of concealing or masking the illegal origin of such property or proving assistance to any person involved in such activities for the purpose of evading legal consequences of his or her actions.

“Terrorism financing” means intentional direct or indirect provision or collection, by any means, of funds with intention or for the purpose of using these funds for performing terrorist acts.

Client means a physical person who has achieved the age of majority and is able to acquire civil rights for himself or herself and fulfil them on his or her own, and also to create civil responsibilities for himself or herself in case of non-fulfilment of such obligations, who has accepted the terms of this document and uses the services of the Website.

Corporate client means a legal entity having separate property and being accountable for its obligations in proportion to its ownership which can purchase in its name and exercise civil rights and bear civil obligations, act as a plaintiff or a defendant in course in the event of non-fulfilment of the accepted terms of this document and use the services of the Website.

JWallet (abbr. – «System») is a processing online centre making payments in currencies of respective payment systems upon request of the Clients.

Administration is a sole owner of the website on the terms of private ownership which ensures organizational, financial and technical support of existence and functioning of the System and the Website. In this way, the Administration ensures the continuous functioning of the Website and free twenty-four hour access for all members of such network.

Parties mean Administration and Clients of the Website.

Website means an Internet resource created for the purpose of operation of the System under the domain name: https://www.jwallet.cc. The website is under organizational management and constitutes private property of the Administration.

1. GENERAL TERMS

1.1. This Policy determines the methods and ways for preventing and reducing possible risks of involving the Administration in any illegal activity related to money laundering and terrorism financing.

1.2. According to the legislation of Hong Kong, the Administration adopts effective internal procedures and mechanisms for preventing money laundering, terrorism financing, corruption and bribery and promptly reacts in the event of any form of suspicious activities on its Clients’ side.

1.3. The terms of this Agreement apply to all visitors and clients of the Website with no exceptions.

1.4. This Policy has been developed and may be changed by the Administration’s unilateral decision. The Administration monitors compliance with this Policy and is not responsible for personally notifying the Clients of any changes in the text of this Policy.

1.5. By accepting the terms of this Policy, the Client gives to the Administration his or her consent for processing of his personal data provided during registration, including, but not limited to, for replying to the Client’s request submitted to technical support service and also for resolving possible claims. The Client also gives his consent for transfer and processing of the above-mentioned personal data to the Administration in case of implementation of this Policy and realization of the features of the Website, and also for resolving the claims related to the implementation of this Policy.

1.6. The current edition of this Policy is accessible through the website at the address: http://jwallet.cc.

2. CLIENT IDENTIFICATION

2.1. During the process of registration in the personal cabinet, the Client will provide to the Administration the following information for identification purposes:
a) Client’s full name, surname;
б) Client’s date of birth;
с) Country of residence or place of stay;
в) Cell phone number and e-mail address.

2.2. During the process of registration in the personal cabinet, the Corporate Client will provide to the Administration the following information for identification purposes:
a) Full name of the Corporate client;
b) Registration number and date of incorporation of the Corporate client;
c) Country of registration or incorporation of legal entity;
d) Address of registration;
e) Contact cell phone number.

2.3. After receiving identification information, the Administration will verify the information stated in paragraphs 2.1.,2.2 of this Policy by requesting respective documents.

2..4. Respective documents for verifying the Client’s identification include the following documents (this list is not exhaustive):
а) for the Client: the image of pages of the passport or another document proving the identity scanned in high resolution which includes Surname, Name (Names), date and place of birth, document number, date of issue and period of validity, country issuing the document, Client’s signature.
b) for the Corporate client: the image of the document confirming the existence of organization scanned in high resolution – Registration certificate and, if applicable, a certificate confirming the legal status of a company, Charter, licenses issued by state authorities (if any) etc.

2.5. In order to verify the Client’s address, the Administration will request to provide one of the following documents containing the correct name of the Client:
a) the image of the bill for services (phone, water-supply, gas-supply, electrical energy supply) issued no earlier than three months ago;
b) copy of bank account extract (current account, deposit or card account).

2.6. Information on the identification of the Client and/or the Corporate will be collected, stored, used and protected strictly in accordance with Confidentiality Policy of the Website and current laws Hong Kong.

2.7. After identifying Client and/or the Corporate Client, the Administration may refuse to provide services to the Client and/or the Corporate client if the activity of the latter conducted through the Website is used for illegal activity.

3. RESPONSIBLE OFFICIAL

3.1. The Administration monitors the activity of the Clients and the Corporate clients for the purpose of detecting any suspicious activity related to money laundering and terrorism financing. Besides using automated monitoring system, the Administration appoints a Responsible official for additional monitoring of transactions.

3.2. The Responsible official is a person duly authorized by the Administration whose duties include ensuring effective implementation and compliance with this Policy. The duty of such Responsible official is to control all aspects of activity of the Administration for fighting against legalization of income acquired in an illegal way, terrorism financing, including, but not limited to, the following methods:
а) collection of identification information on the Client and/or the Corporate clients;
b) creating and upgrading internal policies and procedures for completion, examination, provision and keeping of all reports and records required under applicable laws and rules;
c) monitoring and study of any significant deviations from normal activity of the Website;
d) management of records for the purpose of proper storage and search of the documents, files, forms and journals, regular update of risk assessment system, provision of information required under applicable laws and rules by law-enforcement authorities.

3.3. The Responsible official may cooperate with law-enforcement authorities which participate in the prevention of money laundering, terrorism financing and other types of illegal activities.

3.4. Besides the Responsible official, all employees of the System, including the management, must familiarize themselves with this Policy.

3.5. Responsible officials and employees whose work duties include the matters of fighting against money laundering and terrorism financing will complete the training for compliance with this Policy and the program of fight against money laundering and terrorism financing. The training includes the measures for determining the risks related to money laundering and terrorism financing as well as mandatory actions performed after detecting those risks.

4. PROPER VERIFICATION

4.1. The System performs proper verification of the Client and/or the Corporate client for the purpose of determination and documentary confirmation of the Client’s or the Corporate Client’s identity and also for the purpose of obtaining all necessary information on the purposes and nature of activities planned by them.

4.2. The System receives and documents any additional information on the Client and/or the Corporate client and assesses the risk of money laundering by using the approach based on risk assessment.

4.2. The System receives and documents any additional information on the Client and/or the Corporate client and assesses the risk of money laundering by using the approach based on risk assessment.

4.4. The System ensures the protection of information on the Clients, including their personal data from unauthorized access and disclosure.

4.5. Collection, storage, disclosure and protection of information provided by the Client is performed to ensure proper provision of services by the System through the Website.

5. MONITORING AND DETECTION OF SUSPICIOUS ACTIVITY

5.1. Suspicious activity means any financial activity which may be related to money laundering or terrorism financing.

5.2. Suspicious activity means any Client’s activity bearing the following signs:
а) if the information provided by the Client and proving the legitimacy of sources of monetary funds is false, misleading and significantly incorrect;
b) if the Client refuses to provide or provides insufficient proof of legitimacy of the sources of his or her funds or other assets;
b) if the Client (or a person officially representing the Client) has dubious past or any criminal, civil or normative proceedings were initiated against him;
d) The Client is not interested in the risks, fees or other operational costs of the System;
e) the Client’s account contains a large amount of currency or a total cost of transactions with bank checks is significant;
f) if a large number of transactions is performed from the Client’s account to accounts of third parties and these transactions are not related to the justified business purposes of the Client;
g) if the Client credits funds to an account and immediately withdraws these funds or transfers them to an account of another party or another company without clear business purposes;
h) if the Client’s account has an inexplicably high level of activity and low level of transactions with securities.
i) if another activity of the Client has been declared suspicious by the Administration based on personal observations and experience of the Administration.

5.3. The Administration monitors all transactions and also reserves the right to make sure that any notifications about suspicious nature of transactions have been passed to competent law-enforcement authorities through the Responsible official.

5.4. The Administration may ask the Client to provide additional information and documents if the Client conducts any suspicious transactions.

5.5. In case of suspicious and fraudulent replenishments, including the use of stolen credit cards and/or any other activity of fraudulent nature (including any returns or cancellations of payments), the Administration may block the Client’s account and cancel any payments as well as investigate the nature of suspicious transactions on the Client’s account and, as a result, stop such transactions until the reason of their appearance is established and the investigation is completed.

5.6. The above section is not exhaustive and the Responsible official will monitor the Client’s transactions daily in order to establish if such transactions must be reported and regarded as suspicious or fair transactions.

6. RISK ASSESSMENT

6.1. In accordance with international requirements, the Administration applies the tactics of risk assessment in order to fight money laundering and terrorism financing. By applying the practice of risk assessment to fight money laundering, the Administration will ensure the adequacy of measures for preventing and fighting money laundering and terrorism financing with respect to the established risks.

7. SANCTIONS AND RESPONSIBILITY

7.1. The Client will bear criminal responsibility within the respective jurisdiction for performing financial and other transactions with funds and other property and also for using these funds and other property to conduct entrepreneurial and other economic activity as well as to create organized groups for the purpose of legalization (laundering) of monetary funds and other property obtained in a deliberately criminal way.

7.2. Through this Policy, the Administration warns the Clients that civil and criminal punitive sanctions for money laundering and terrorism financing may amount to hundreds of thousands or even millions of dollars and the term of criminal penalty may amount to 10 (ten) years of imprisonment. Besides, state authorities may confiscate any property involved in the criminal violation of laws and statutory acts, including companies, bank accounts and any other assets which may be related to criminal violations.

7.3. Under the terms of this Policy, the Administration represented by the Responsible official will be liable for:
а) taking respective legal and/or disciplinary measures against persons guilty of prohibited behaviour;
b) developing and ensuring effective internal control in order to prevent prohibited behaviour;
c) conducting intensive and operative investigations if the prohibited behaviour occurs;
d) notifying competent state authorities of any suspicions regarding the prohibited behaviour;
e) notifying of any internal and external suspicions or incidents related to the prohibited behaviour.

8. CHANGES AND ADDITIONS

8.1. This Policy may be changed at any moment at the Administration’s own discretion. By accepting the terms of use of the System the Client acknowledges and agrees that he or she will periodically check this Policy for any possible changes and additions.

8.2. If the Client refuses to accept the changes to this Policy, then he or she may not use the System. In this case, the Client may not use the features of the Website and the Client will be deprived of the opportunity to use the features of the Website.

If you have any information about illegal activity, please contact our support service: [email protected].