KYC & AML Policy For Preventing Financial Crime

INTRODUCTION

Island Computer Limited (“Island Computer”, “we” or “us”) is committed to providing safe, compliant and reputable services to our customers.  As a company, we pride ourselves on the integrity and transparency of our business.  For this reason, Island Computer adopts rigorous anti-money laundering, counter-terrorist financing and sanctions (“AML/CTF”) procedures and other know-your-customer (“KYC”) policies.  

Our commitment to preventing financial crime helps protects the integrity of the digital assets ecosystem and you.

This document provides an overview of some the key aspects of our approach.  It also describes the types of things that we may ask you to do.

 

2     WE TAKE OUR OBLIGATIONS SERIOUSLY

Island Computer is doing business in Hong Kong and its infrastructure is physically located in Hong Kong.  Island Computer is also incorporated under the laws of Hong Kong.  Accordingly, Island Computer is subject to Hong Kong law, including a range of legislation, rules and regulations that restrict or prohibit payments, transactions, services and dealings with assets having a proscribed connection with certain countries, individuals, groups or entities subject to international sanctions or associated with terrorism, money laundering, weapons of mass destructions or other criminal activity.

Importantly, Island Computer may be required to avoid, terminate or suspend certain customer relationships and/or transactions.  It must also report any relevant knowledge or suspicion to Hong Kong’s Joint Financial Intelligence Unit (“JFIU”) before dealing with that person and must avoid prejudicing any investigation by “tipping off’.  We may also be required to provide information related to AML/CTF and other legislation to other authorities in Hong Kong and/or other jurisdictions (including securities, customs or tax authorities) upon a proper request being made by those authorities. 

Various other requirements may also apply to Island Computer which may impact our ability to deal with any customer.  For example, we need to take appropriate precautions when dealing with politically exposed persons.

 

3     WE OPERATE IN A GLOBAL MARKETPLACE

Island Computer also operates in a global marketplace.  As such, we also take into account international standards and developments.  Importantly, Island Computer reserves the right to refuse access to our services or to prohibit specific payments, transactions, services and dealings and/or to enter into any transactions that may be sanctioned under international programmes or which otherwise have a direct, or indirect, connection with certain persons from or in jurisdictions that pose elevated risks.  As noted above, we may also have reporting obligations in those jurisdictions.

 

4     WHAT DOES THIS MEAN FOR YOU?

Island Computer takes a risk-based approach to AML/CTF and KYC compliance programme. 

There are three key limbs to this programme that may involve you:

(a)            Customer due diligence.   Island Computer carries out customer due diligence to identify and verify our customers and any relevant connected persons.  This includes screening against relevant commercial databases to ensure we meet our obligations.  Enhanced due diligence may apply in certain scenarios, and the requirements that apply to individuals, corporations, trusts and partnerships differ. Further details about the documents and other information we require are available on request from Island Computer.  

Importantly, we need your help with this process.  We cannot provide any services until our due diligence procedures have been completed. 

(b)            Transaction screening and monitoring.  We also undertake transaction screening and ongoing monitoring throughout the course of our relationship with the customer to ensure we meet AML/CTF requirements.  As a result, we may ask you certain questions about the transactions to be entered into between us.  We also take potential abuse of our services very seriously.  This could result in an immediate suspension of access to our services and reporting to the relevant authorities.

(c)            Ongoing due diligence.  We may ask you for additional information to ensure that the information and materials we have are up-to-date and relevant. 

Our due diligence procedures are relevant to both preventing financial crime, as well as ensuring that we continue to meet our legal and regulatory obligations.  For example, there are certain services that we cannot provide to persons from certain jurisdictions. In order to comply with regulatory requirements, there may also be additional products or services which we provide in the future that will require different information from you for regulatory purposes (e.g. if you qualify as a professional/accredited investor for certain products).

 

5      RECORD KEEPING AND REPORTING 

We maintain records as required by law and in accordance with our data protection policies and procedures.  As a guide, we generally maintain customer due diligence and transaction records for at least seven (7) years. 

On certain occasions, we may be required by law to submit information to regulators or other authorities in Hong Kong and potentially abroad.  This may be required without prior notification or consent.   By way of example, we are required to submit a suspicious transaction report to the JFIU in Hong Kong in certain circumstances, including where we suspect that certain property (including digital assets) represent the proceeds of crime.  We will generally not be able to inform you of such reports, as it is a criminal offence to do so. Without limitation, we may also be required to report certain tax information regarding transactions undertaken by you, either to local or international tax authorities, and may not be able to inform you of that information. 

Contact us, anytime

Please contact us anytime if you have any questions. 

 

Last updated: 25 November 2018. 

© 2019 Island Computer Ltd.