Anti-Money Laundering and Customer Due Diligence Policy

This policy applies for common terms regarding Anti-Money Laundering (AML) and Customer Due Diligence (CDD), commonly also known as Know Your Customer (KYC) processes of Sapphire Coin (“SPH”). The process and policy is provided to you by the legal authority, Click Team OÜ (“Company”).


CONSIDERATION, ACCEPTANCE

Company will present the buyer with the terms and terms are made available publicly through the SPH website. The usage of the service or site, the purchase or registration to the wallet is the acceptance of these this policy.

WHO NEEDS TO DO KYC

Everyone who purchases SPH tokens, uses the wallet system or plays the ClickJackpot (“CJ”) game, must do and go through the CDD process.

For the SPH token sale, the buyer must identify himself/herself with sufficient documentation to prevent money-laundering and fraudulent activities in the system or via the system/company.

CDD (individual)

Each individual is required to register an account/wallet individually. This person is solely responsible for this account.

As part of the CDD process, following documentation shall be made available for the Company. More information may be required later if needed. The service may be halted or stopped during the CDD process if seen necessary by the Company.

  • A clear and legible copy of the front pages of your ID (and back, if necessary). This can be a passport or driver’s license or national ID card including the photograph;
  • A clear and legible copy of a recent utility bill or bank reference letter or bank statement, or government document showing your name and residential address.
  • A selfie video with a clear image to verify liveness and facematch with your ID.

CDD (company)

Each buyer is responsible for their purchases separately. For companies, a more manual process is required and requires additional documentation.

The following documents from companies are needed:

  • Certificate of Incorporation
  • Memorandum and Articles of Association
  • Register of Directors
  • Copy of any shareholder nominee agreement
  • Copy of any power of attorney granted
  • List of all beneficiary owners / shareholders with significant control (any who own more than 25% of the company) and directors (at least 2)
  • For directors or shareholders the following:
    • Clear and legible copy of the front pages of your passport or driver’s license or national ID card including the photograph (and the back pages if needed);
    • A clear and legible copy of utility bill or bank reference letter or bank statement showing your name and residential address
  • All documentation have to be Certified or Notarized through an appropriate person. All documents that are in a foreign language must be accompanied with a certified English translation

QUESTIONS

In addition, as part of the AML process and policy, each registered user shall provide information and confirm following:

  • Do you, an immediate member of your family, or a close associate, occupy a senior public, political, governmental, military or judicial position?
  • “I certify/confirm that the source funds used in this transaction are not directly or indirectly the proceeds of criminal enterprise, neither are they intended directly or indirectly to support terrorist activities of any kind whatsoever”

SCREENING

We may or will screen the data against popular sanction lists including, but not limited to:

  • OFAC Consolidated List: Both parts of the United States’ consolidated sanctions list, both the specially designated nationals (SDN) and the non-SDN entities published by the Office of Foreign Assets Control (OFAC).
  • US Denied Persons List: The Bureau of Industry and Security publishes this list of entities which are relevant with regards to export controls.
  • Swiss SECO Sanctions/Embargoes: United Kingdom’s consolidated international sanctions list.
  • EEAS Consolidated List: As part of the Common Foreign Security Policy the European Union publishes a sanctions list implemented by member states.
  • INTERPOL Red Notices: International arrest warrants published by INTERPOL with a view to extradition of the wanted individuals.
  • GB Insolvency Disqualified Directors: Individuals which have been disqualified from holding the post of a company director in the United Kingdom following a court decision.
  • CoE Parliamentary Assembly: The Council of Europe’s parliamentary assembly is composed of members of national parliaments from European countries including Turkey and Russia.
  • Every Politician: An index of all national members of parliament in the world active within the past 15 years.
  • UN Consolidated Sanctions: The Security Council’s set of sanctions serve as the foundation for most national sanctions lists
  • For a company or legal entity we may screen against the aforementioned lists confirm the existence and good standing in any of the official company registries
  • We may use 3rd party service for this screening

BLOCKAGE

We may block any purchase or any access to the services at any point at our own will, based on our AML policy change or suspect to a possible fraudulent activities without any pre-notice. This block may be user, geographical or based on any other contraint.

AML

We will screen the cryptocurrency (e.g. Bitcoin or Ethereum) addresses against a common blacklists and known security discrepancies to make sure the funds were not derived from any illicit sources, and there is no indication of money laundering (placement, layering, integration) or otherwise, either manually or using a 3rd party service. Each payment is processed through PayApi anti-fraud operations and may be rejected.

OUTSOURCING

Company may outsource the validation of CDD documents and screening (or parts of it) to a 3rd party compliance firm who will maintain these files in their servers for later use.