KYC/AML Policy

Followine S.r.l has adopted this KYC / AML policy in order to prevent and mitigate the possible risks of involvement in any type of illegal activity.

Both national and international regulations require the implementation of an effective internal system as well as procedures to prevent money laundering.

1. VERIFICATION PROCEDURES - KYC

1.0 The first step of the verification process is to compile the KYC form with a valid email and your name. Followine staff will require more information by email.

1.1 The identity verification procedure requires the customer to provide documents, data and / or information (eg national ID, international passport, bank statement, utility bill). The Company reserves the right to collect additional user identification information.

1.2 Company will verify the authenticity of documents and information provided by users. All legal methods will be used to carry out the necessary checks. Furthermore, it reserves the right to monitor certain Users who have performed actions that may be considered risky and / or suspect.

1.3 Company reserves the right to verify the identity of the customer on an ongoing basis, in particular when the information acquired during the identification process has been changed or the activity of the customers may seem suspicious. Furthermore, it reserves the right to request updates to the documentation at any time.

The user identification information will be collected, stored, shared and strictly protected in accordance with the Privacy Policy (click here) in compliance with the provisions of EU Reg. 2016/679. The data taken during the procedure will not be profiled.

1.5 The Purchaser agrees to perform the KYC procedure by providing the information requested by the Company.

1.6 During the account registration process the buyer provides the following identification information to the Company:

  • a) Name and Surname
  • b) date and place of birth;
  • c) Country of residence and complete address
  • d) mobile phone number and an e-mail address.

1.7 Provided the information referred to in the previous point, the client will be asked for the following documents:

- Physical person

  • a) A scanned copy at high resolution or a photo of the passport or any other national identity document (from which the name and surname, date and place of birth, document number, date of issue and expiration, country of issue and signature of the buyer);
  • b) a selfie with the document referred to in the previous letter
  • c) a scanned high resolution copy of a bill (telephone, water, electricity, etc.) no older than 3 months or a high resolution scanned copy of the bank statement.

- Legal Entity:

  • a) Constitutive Act;
  • b) Document attesting the registration in the business register; the VAT number;
  • c) Documents required for natural persons, by the legal representative.

1.8 The Purchaser undertakes to cooperate and provide any information and documents deemed necessary by the Company. In the event that the automatic procedures fail, the Company will contact the Purchaser by e-mail or other means to obtain the necessary information and documents.

1.9 The Company reserves the right, in its sole discretion, to decide whether or not to sell tokens to a particular buyer.

2. MONITORING - AML

2.1 The Company undertakes to apply a strict anti-money laundering policy.

Money laundering activities means any activity carried out in an attempt to misrepresent the origin of funds actually acquired through illegal and / or illicit activities such as funds acquired through legal activities.

2.2 The Company implements transactions in order to identify any financial assets that may constitute or are connected to recycling activities.

2.3 All Token buyers issued by Company acknowledge, commit and accept the following terms:

  • a) The buyer will comply with the AML policy adopted by the Company.
  • b) The Purchaser agrees to cooperate fully with Company. This involves the provision of information that the Company may require regarding the client's business details, account usage, financial transactions, etc
  • c) Company reserves the right to delay or interrupt any transfer of funds if there is reason to believe that the completion of such transaction could constitute a violation of the relevant regulations. In addition, it reserves the right to suspend or terminate any account or freeze funds if there is reasonable grounds to believe that the account will be used for illegal and / or fraudulent activities.
  • d) The Company reserves the right to share customer information with:
    • - Investigative agencies or any authorized officials;
    • - Public bodies, law enforcement agencies and judicial authorities;
    • - Regulatory bodies and financial institutions.

3. COMPLIANCE

3.1 The Compliance Officer, a subject authorized by Company, is responsible for ensuring the implementation of the AML / KYC policies.

3.2 It is the responsibility of the Compliance Officer to oversee all aspects and procedures set forth in this policy, including, but not limited to:

  • a) Collection of user identification information;
  • b) Update and implementation of internal policies and procedures for the completion, revision, presentation and conservation of all the relationships required by law.
  • c) Monitor the transactions and investigate any anomalous and / or suspicious activities / behavior;
  • d) Perform periodic risk assessment;
  • f) Provide the required information to law enforcement agencies.

30/01/2021