Policy of anti-money laundering and “know your customer”

The purpose of the Policy of the anti-money laundering and “Know your customer” (“KYC Policy”) is to prevent activities of money laundering and financing of terrorism in the Service by complying with the requirements of international and national legislation and implementation of procedures for the identification of users.

According to KYC policy, “STEEPAY”, “we”, “us” or “our” refers to the company STEEPAY LP, including, without limitation, its owners, directors, investors, employees and other related entities. Depending on the context, “STEEPAY” can also refer to services, products, web site, content or other materials provided by STEEPAY.

This policy is an integral part of the terms of use. When you accept the terms of use, you automatically agree with the Policy of KYC.

Capitalized terms not defined in this KYC Policy have the meaning defined in the Terms of use.

THE LEGAL BASIS

The regime against money laundering in the United Kingdom is set out in the following legislation:

Legislation
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2015_141_R_0003&from=ES
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R0847&from=LT
http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf
http://www.legislation.gov.uk/uksi/2007/2157/contents/made
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/468210/UK_NRA_October_2015_final_web.pdf
http://www.legislation.gov.uk/ukpga/2002/29/contents
http://www.nationalcrimeagency.gov.uk/publications/464-2014-sars-annual-report/file
The FATF Recommendations, 2012. http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf
Glossary to the The FATF Recommendations, 2012. http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf
The FATF Recommendations, 2012. http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf
Article 4.1(1) of the capital requirements regulation. http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32013R0575
Glossary to the The FATF Recommendations, 2012. http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf

Compliance with KYC policies STEEPAY will ensure compliance with all relevant laws and regulations.

KYC

KYC applies to users suspected of illegal transactions. We may ask you to provide the following documents for identification:

The documents proving the identity:

1. National and/or international passport;
2. A national identity card.

Proof of address:

1. Copy of utility bills;
2. Phone bill;
3. Statement from the Bank.
4. Other documents such as driving license, etc.

USER IDENTIFICATION

STEEPAY has the right to take various measures, including the user identity, to prevent money laundering, terrorist financing and other illegal activities by monitoring suspicious user activity, i.e. the activity that has any elements or characteristics of prohibited conduct listed in the Policy to combat fraud.
STEEPAY does not identify each user in general. However, STEEPAY checks users whose activities are suspicious.
STEEPAY has the right to suspend the account associated with the suspicious activity, and ask the owner of such account to go through the procedure of KYC.

USE OF PERSONAL INFORMATION

All personal user information and documents collected in connection with the KYC will be used, stored and protected in accordance with our privacy Policy.

OPERATIONS MONITORING

STEEPAY will closely monitor the transaction in case of suspicious activity. When such suspicious activity is detected, the User will be required to undergo KYC, otherwise access to the account and all funds will be frozen until the dispute is resolved.

AMENDMENTS

This KYC policy may be changed at any time at the sole discretion of STEEPAY. You acknowledge and agree that it is solely your own responsibility to periodically check the Policy of KYC and receive notifications about changes and additions.
If you do not want to accept the modified and/or amended KYC policy, you should not continue to use the Service. Your continued use of the Website and/or the Service following the posting of changes to KYC Policy will be deemed as your acceptance of those changes.

Anti-fraud policy

This anti-fraud Policy sets STEEPAY in the prevention and deterrence of fraud, corruption, collusion, money laundering, terrorist financing and any other criminal acts in the activities of STEEPAY.
STEEPAY is committed to high legal, ethical and moral standards. The public, STEEPAY partners and users have the right to expect that STEEPAY implements a significant level of protection from any illegal activities.
The anti-fraud Policy was implemented in accordance with applicable local and international laws.

Definitions

Capitalized terms used in this anti-fraud policy have the following meanings:

Prohibited behaviour means any unlawful conduct that involves fraud, corruption, money laundering, conspiracy, financing of terrorism and any other criminal conduct.
Fraud means the use of deception with the intention to pursue personal interests and harm the interests of users and/or STEEPAY.
Corruption means offering, giving, receiving or soliciting, directly or indirectly, anything of value to influence the actions of another party improperly.
Money laundering means the scheme of financial transactions, the purpose of which is to conceal the identity, source, and destination of illegally obtained money.
Collusion means an arrangement between two or more parties, aimed to achieve an improper purpose, including influencing improperly the actions of another party.
Financing of terrorism means providing or collecting funds by any means, directly or indirectly, with the intention of using them or knowing that they will be used, in whole or in part to perform any of the offences against terrorism.
Criminal conduct means a crime in any part of the world or would constitute a crime in any part of the world if it occurred there.
Commissioner for anti-fraud — a person authorized to monitor, prevent and investigate cases of prohibited conduct and is responsible for the proper implementation of Policies to combat fraud.

Capitalized terms not defined in this Policy to combat fraud, have the meanings provided in the Terms of use.

Fraud investigation
In the case of reasonable suspicion that prohibited conduct occurred, STEEPAY has the right to carefully examine this question using recognized and legitimate investigative techniques.
Commissioner for anti-fraud is the first line of detection, investigation, and protection in preventing prohibited conduct in the course of the evaluation process of users and transactions.
In some cases, external researchers may be involved in STEEPAY to gather sufficient evidence to refer the case to the relevant authorities. Responsibility for the management of third parties is the responsibility of the Commissioner for anti-fraud.

During the investigation, the Commissioner for anti-fraud is responsible for:

The collection of any information concerning an alleged prohibited conduct, including information about Users and certain transactions;
Report on his findings to the STEEPAY administration and the relevant authorities and to any third party in case it needs to know this information.
Commissioner for the fight against fraud has the right to open, pursue, close and report on any investigation of prohibited conduct, within its competence without prior notification, consent or interference of any other person or entity. All investigations must be conducted objectively and confidentially.
We reserve the right to block the user funds in the account until investigation is made to ensure prompt and complete investigation procedure.
All users are obliged to promptly, fully and effectively cooperate with the Commissioner in combating fraud, including answering relevant questions and executing requests for information and documentation.
All information and documents collected and created during the investigation of prohibited activities that are not yet in the public domain must be strictly confidential. The confidentiality of the information collected will be respected in the interests of the persons concerned, and in relation to the integrity of the investigation.
In particular, during the investigation of prohibited conduct confidentiality will be respected, because it is not contrary to the interests of the investigation.
Commissioner for the fight against fraud needs to disclose such information and documents only to those persons or entities who are authorized to receive them, if necessary.

liability of the Parties

Commissioner for anti-fraud bears the primary responsibility for preventing, monitoring and investigating cases of prohibited conduct.
In connection with the above measures, we can authenticate any User and/or transaction in accordance with the Policy of KYC to identify evidence of prohibited conduct.
In connection with the policy to combat fraud we are responsible for:

? Taking appropriate legal and/or disciplinary measures against the perpetrators of prohibited conduct;
? The development and effective implementation of internal controls to prevent prohibited conduct;
? Providing intensive and prompt investigation, if a prohibited behavior takes place;
? Report on any suspected prohibited conduct to appropriate authorities;
? Ensure that the Commissioner for anti-fraud can report any internal and external suspicions or incidents of prohibited conduct.

The application of the user

Using our service, you warrant that you do not intend to commit any prohibited actions described here. In addition, you consent to any checks in connection with the investigation in accordance with the Policy on anti-fraud, and you agree to provide full and prompt cooperation with the Commissioner for the fight against fraud in the framework of his investigation.

Changes and additions

This policy to combat fraud may be changed at any time at the sole discretion of STEEPAY. You acknowledge and agree that you assume the responsibility to periodically review anti-fraud Policies and be notified about changes and additions.
If you don’t want to adopt the amended Policy against fraud, you should not continue to use the Service. Your continued use of the Website and/or the Service following the posting of changes to the Policy on the fight against fraud will be deemed as your acceptance of those changes.
If you have information about illegal activities, please contact our support team: support@steepay.com