AML & KYC Policy

Risk Management Solutions

Arabtizor holdings Inc and it’s affiliates and subsidiaries are applying Anti-Money Laundry (AML) and Know Your Customer (KYC) policies and procedures in due diligence to prevent any overseas potential risk to breach our database over the offered services and products, therefore, we keep assess the efficiency of our applicable AML/KYC policies and procedures to reach best practices in industry and to match regulatory requirements.

We are committed to protecting your interests against potential instances of money-laundering and related financial crimes and promoting legal and transparent trade in Digital Assets, This Anti-Money Laundering & Know-Your-Customer Policy (“AML & KYC Policy”) describes the policies and procedures relating to prevention of money laundering, financing of terrorism, and related illegal activities. The Company has prepared AML & KYC Policy to ensure the highest possible voluntary compliance under national and international AML standards.

This AML & KYC Policy applies uniformly to any User desirous of availing the Services or otherwise using or benefitting from the use the Website. It is imperative that you read this AML & KYC Policy before using the Website. By using the Website, you are expressly consenting to be bound by the Terms of Use and consequently this AML & KYC Policy. You must stop using our Services and/or the Website if your use results in committing/attempting to commit any criminal offences.

Introduction

The terms “We”, “Our”, “Company” , “Arabtizor” and “Us” refers to Arabtizor Holdings Inc and any of its subsidiaries, and the terms “User”, “You” and “Your” refer to a User of our Website and/or any of our services and/or products. The capitalized terms used in this AML & KYC shall have the meaning of Anti-Money Laundry and Kow Your Customer terms for the purposes of relevant local and international laws and standards applicable from time to time. This AML & KYC Policy is a part of and incorporated within, and is to be read along with, our Terms of Use (the “Terms”, the”Terms & Conditions”) and our Privacy Policy. You have to be aware and view the current version of these policies which is in effect from time to time over our website.

We have the right, at any time, to change or modify the terms and conditions applicable to your use of our Services and Products, or any part thereof (including this AML & KYC Policy), or to impose new conditions, including, but not limited to, adding fees and charges for use. Such changes, additions or deletions shall be effective immediately upon notice thereof. This notice may be given by means including, but not limited to, updating the “Last Updated” field at the top of this document with the date of the current revision. Any use of our services and products by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. Any amended Terms will apply prospectively to use of the Services after such changes become effective. It is important therefore that you review our Terms & Conditions and Privacy Policy and the Risk Disclaimer on a regular basis to ensure that you are familiar with the terms in force from time to time and/or any changes made to them. If you do not agree to any amendments, you must discontinue using our services or products and contact us to terminate your account/registration/order or any kind of business relationship might be established between you and Arabtizor holdings Inc . We may regularly furnish regulators or law enforcement agencies the details of any transactions taking place on the Website and such other information as deemed necessary by us.

Risk Assessment 

We will undertake a risk assessment based on all/any of below :

(A) sufficiency and adequacy of identification documents submitted by you in any stage of service we choose before the actual delivery of the purchased services and/or products and/or digital asset(s) and/or Digital token(s) .

(B) your social and/or financial status if such requirements raised by regulators locally or internationally.

(C) nature and other similar information about your business/vocational activities.

(D) guidance notes circulated by various governmental and/or inter- governmental organizations.

We may internally categorize you as a low-risk, medium-risk, or a high-risk User on the basis of the aforementioned assessment.

We will keep your risk categorization and related data confidential at all times, subject to any requests received from a competent law enforcement authority. In order to maintain the integrity of the risk assessment process, the results of your risk assessment and/or categorization will not be disclosed to you either.

Important: If you violates any of our AML/KYC policy terms by any mean and/or hiding any real information and/or doesn’t commit to our AML/KYC policy requirements, then you understand and agree that we have the full right to cancel your purchase transaction completely and refund your paid amounts over same payment channel or otherwise upon our steering committee decision (after deducting the transferring fees and any other operational fees) while in such case(s) -without limitation- you agree to accept this action against you without any objection by you or any one can act on behalf of you.

Levels of Ordering, Registration and Verification

We are applying user-friendly process to receive our service(s) and product(s) in best way for both parties, the company and the user as follow:

(A) Ordering Level: in this level we don’t ask any additional information from you to ease your purchase process, except what we need of information to book your order into our records and enable us to send you the “Order Confirmation” here under necessary information in this level of purchase:

  • Your Email Address.
  • Your Order Quantity.
  • Your Payment Details.

At the time of transferring your purchased digital asset(s) and proceeding to registering you as a User into ADAX as our subsidiary online service into stage one of default account types “General Account” which is not verified category as Crypto to Crypto exposures only; then you HAVE to provide all required identity information and ID verification as a MUST and requirement to transfer your token(s) and complete your registration process upgrade to be in verified account model over the categories of “Standard Account” and “Business Account” , that will help us to apply our AML/KYC compliance policy and facilitate the other supplementary services accompanied with your purchased digital asset(s) and necessary to be active exposure such as; ADAX account trading options, exposures and transferring limits, requests to transfer any funds from/to your Linked Bank Account or third-party digital asset wallets, …etc; meanwhile periodically for purposes of updating records and on-going due-diligence (as specified under the AML Laws and Standards, or upon being directed by appropriate enforcement authorities), be required to take part in the User identification and verification process.

(B) Registration Level: this level is the verification process level which including two requirements as follow:

  • Complete your full registration form and provide required documents to verify your real identity and enable you create your ADAX account in the designed account type category (General, Standard, Business).
  • Provide your digital wallet address (if needed) which we will help you how to generate it only, to enable you receive your purchased digital asset(s) securely according to your account category.

The registration process of your purchased digital asset(s) tokens and transferring to your digital wallet address is subject to your account type category and your full commitment to these requirements and the purchase process can be cancelled if you didn’t commit in full to our AML/KYC policy, hence; if your verification process passed successfully our risk assessment procedures over this level upon applicable laws and regulations, then we will proceed further to transfer your digital asset(s) tokens to your provided digital wallet and register your account as well into ADAX as the leading digital assets exchange and online floor which listing your Arab digital assets tokens to be exchangeable Cryptos in market against Cryptos and in next stage against fiat transactions.

Important: If your risk assessment didn’t pass our minimum level of security over our applicable AML/KYC policy terms and requirements, then you understand and agree that we have the full right to cancel your purchase transaction completely while the ordered tokens will not be transferred to you and a refund process of your paid amounts will be acted over same payment channel or otherwise upon our steering committee decision (that will be after deducting the transferring fees and any other operational fees) while in such case(s) -without limitation- you agree to accept this action against you without any objection by you or any one can act on behalf of you, because its your sole responsibility to evaluate in advance if your identity is under any restrictions or sanctions might cause the cancellation of your order if it was applicable regulations with the counter party you are dealing with.

We may collect the following information for the purposes of verification of identification:

  • Individual Users: (without limitation) Name; date of birth; email address; phone number and residential address; photograph; copies or certified copy of any Valid Documents; documents pertaining to business/financial status of such User (if prescribed by the Company);..etc
  • Business Users: (without limitation) Business name; name, contact-details, photograph, and copy of Valid Documents of the authorized representative, one certified copy each of the certificate of incorporation/registration Certificate (as the case may be); memorandum and articles of association/partnership deed (as the case may be); board resolution/other authorization documents giving authority to the representative chosen to execute transactions on the Website;…etc.

You must promptly update us of any changes to the customer information provided to us within three days of effecting such changes. You must file a fresh proof of address within three (3) months of effecting any changes to the address mentioned as per the ‘proof of address’ submitted by you over email.

Delegation to check identity

By your purchase for any of our services and/or products, you authorize us to do all necessary checking process to verify your real identity over any government or sanction lists wherever and whenever we find it necessary under any process category. so we may require you to furnish such other details as may be deemed necessary to verify your identity if we either (i) cannot verify your identity, or (ii) have a reason to believe that you are a person or entity whose details are provided in any official, governmental or intergovernmental sanction list. For the purpose of this AML & KYC Policy and our Terms of Use, “Sanction Lists” are lists available to check individual and entities identities to prevent any unauthorized suspicious exposures to intervene into our customer database.

We reserves the right to refuse registration to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time without justification behind this termination. Without limiting the generality of the foregoing, this includes, but is not limited to, anyone from or in jurisdictions that do not meet our international standards to keep highest level of professional clean environment; anyone that is a Politically Exposed Person; anyone on an official, governmental or intergovernmental Sanction Lists; upon reasonable request or direction of a competent enforcement authority; or, anyone that fails to meet any customer due diligence standards, requests, or requirements of Arabtizor holdings Inc and/or ADAX as our subsidiary online service.

If we believe any information obtained from the User hereunder is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; or (d) appearing on any Sanctions Lists, we may in our sole discretion either refuse or terminate (as the case may be) the purchase transaction and do not proceed the registration of ADAX account or require such User to verify the Valid Documents submitted by it again. We may also, in our sole discretion, refuse to accept any purchase order request and /or open any new ADAX accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Website of Arabtizor or ADAX if we are unable to verify any information due to non-cooperation by the User and breaching the notice timelines , or if such transactions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.

In case of a legal entity, you must identify the Beneficial Owner and also assist in verification of the identity of such Beneficial Owner and any individual who purports to act on behalf of such legal entities. In this regard, a “Beneficial Owner” means: (A) In case of companies, the natural person who has ownership of over 25% (twenty five percent) of the shares, is entitled to over 25% (twenty five percent) of the profits, or has the power, directly or indirectly, to appoint or elect more than half of the board of directors of such company, as the case may be; and, (B) In case of partnership firms/Limited Liability Partnerships, the natural person(s) who has ownership of over 15% (fifteen percent) of the capital or is entitled to over 15% (fifteen percent) of the profits of such firm, as the case may be.

We may also require you to certify that your Linked Bank Account is held only with a scheduled commercial bank which is compliant with all know your customer (KYC) procedures mandated under the applicable laws. For this purpose, we may require you to furnish this certification in such format as may be prescribed by us.

Identity Verification Procedures

We may, at our sole discretion, at the time of transferring your purchased digital asset(s) and/or initiation of your user registration process into ADAX (adax.ae) as our subsidiary, we may request one or more appropriate third-party service provider to assist us in authentication and verification of the Valid Documents and other incidental details provided by you. In addition to the above, we reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We will use the following non-documentary methods of verifying identity: (a) Confirming validity of email; (b) Confirming validity of telephone number or bank account number; and (c) Confirming your location using, among others, your IP address; all of which may be carried out by an automated or manual process and in for any account category we see as appropriate .

We may monitor and flag for review all transactions where the amounts involved exceed our internal limits , limits specified by local or applicable laws, official guidelines, or industry best practices such as -without limitation- account categories. In addition to the above, we may regularly monitor, through both manual screening and use of software-based algorithms, all transactions executed and/or attempted to be executed on our Website(s), in order to promptly identify and highlight any suspicious activity, which includes without limitation, activities that:

  • appear, to a person acting in good faith, akin to collection of funds to be used, either in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts;
  • appear, to a person acting in good faith, to have been structured in a manner of unusual or unjustified complexity in order to avoid triggering any reporting requirements;
  • appear, to a person acting in good faith, to have been transacted for a malafide purpose or where a sound economic rationale cannot be
  • appear, to a person acting in good faith, to signal possible ‘money-laundering’ activities, as defined under applicable laws.
  • appear to be unusual due to the reason of being inconsistent with any User’s risk profile, expected usage pattern or sophistication. The extent of monitoring shall depend on various factors including upon each User’s risk

On detection of any suspicious activity, we reserve the right to take appropriate actions without any prior notification to the User, which includes, without limitation, (i) cancel purchase transaction and suspend token transferring process, (ii) terminating his ADAX Account, (iii) restricting and/or blocking further access to our Website(s) and/or services, and (iiii) notifying the appropriate enforcement authorities regarding the suspicious activities of any User.

Records Retention

Under applicable AML Laws and Standards, we are required to maintain and preserve the following information and/or data:

  • Records of all transactions executed by you on our Website, for a period of time specified by law from the date of each.
  • Records of all suspicious transactions, trans-national transactions, and transactions wherein the amounts involved exceed a specific amount(s), whether executed or attempted, for a period of at least 10 (Ten) years, including but not limited to the information about the nature and value of the transactions, parties involved in such transactions, and information about the date of remittance, in addition to reporting the same
  • Identification records of Users (including but not limited to the Valid Documents submitted, during the subsistence of and for a period of time specified by law from the date of termination of such User’s.

Disclosure

In order to improve the integrity and transparency of transactions on the Online Platforms, you are encouraged to report, to our Compliance personnel, any information which you are privy to or become privy to, regarding any suspicious transactions, or transactions you find or have reason to believe are dubious in nature.

In order to ensure compliance with this AML & KYC Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as email address provided by you will be considered the main contacting channel to notify you in addition to the website(s) updates. Where you are required to share any information according to the procedures contained in this AML & KYC Policy, such communication may be made by you electronically by sending an email to our Compliance personnel at:  [email protected]