KYC Policy

The KYC policy is performed in accordance with the TERMS AND CONDITIONS and in accordance with the instructions and policies on this website. Know your customer policies have become increasingly important on a worldwide basis, especially among banks and other financial institutions, in order to prevent identity theft, money laundering, financial fraud and terrorist activity. Genesis holds a zero-tolerance fraud policy, and is taking all measures possible to prevent it. Any fraudulent activity will be documented and all accounts related to it will be immediately closed.

Prevention Genesis aims to ensure the integrity of any sensitive data it obtains, such as your account information and the transactions you make, using a variety of security measures and fraud controls. Securing your electronic transactions requires us to be provided with certain data from you, including your preferred deposit method.

The Company’s compliance officer is always entitled to ask any Client for additional documentation to complete proper KYC/AML procedure and if there are any suspicions on money laundering or dishonest activities. The Company is entitled to stop any cooperation with the client or not to enter it if the client failed to refute any suspicions. The Company is entitled to report any unlawful activity.

High-risk clients definition. The Compliance Officer will provide and will continuously update a list of the types of Clients that the Company considers to be of ‘high risk,’ such that enhanced due diligence procedures are warranted compared to the routine Client Identification Procedures.

High-risk clients identification The Company shall take reasonable steps to ascertain satisfactory evidence of a High-Risk Client’s name and address, its authority to make the contemplated investment. The Company will obtain certain of the following, as appropriate under the circumstances. High-risk Client identification is an enhanced due diligence procedure, which includes more strict requirements for compliance.

Following are the “red flags” for clients, who pose a high money laundering risk:

The following are some of the red flag symptoms of cryptocurrency money laundering:

Transactional behavior: Suspicious cryptocurrency transaction patterns, such as high transaction frequency in a short period of time or quick deposits and withdrawals of funds into a newly formed account.

Geographical risks: Cryptocurrency transactions that are carried out into or out of high-risk nations or jurisdictions, or that send currency to exchange outside of the customer’s home country. 

Structured transactions: Multiple cryptocurrency transactions that are deliberately structured in amounts that do not trigger reporting thresholds. 

Anonymous transactions: Criminals that want to take advantage of the anonymity of cryptocurrencies can utilize privacy coins, trade on unlicensed exchanges, or trade through proxies. Criminals may also try to use the same IP address to operate numerous cryptocurrency wallets anonymously.

Inadequate CDD: Cryptocurrency transactions involving accounts with insufficient customer due diligence who have refused or avoided inquiries for identifying information.

Money-mulling: Customers who are elderly or financially vulnerable, or who appear to be unaware of the risk associated with cryptocurrencies, may be exploited as mules to carry out transactions for money launderers.

The following are some examples of high-risked clients:

A Senior Foreign Political Figure, any member of a Senior Foreign Political Figure’s Immediate Family, and any Close Associate of a Senior Foreign Political Figure (Politically Exposed Persons or PEPs defined by FATF recommendations are also included in this category).

A Senior Domestic Political Figure, any member of a Senior Domestic Political Figure’s Immediate Family, and any Close Associate of a Senior Domestic Political Figure (Politically Exposed Persons or PEPs defined by FATF recommendations are also included in this category).

Any Client resident in, or organized or chartered under the laws of, a Non-Cooperative Jurisdiction.

Note: Non-Cooperative Jurisdiction means any foreign country that has been designated as non-cooperative with international anti-money laundering principles or procedures by an intergovernmental group or organization, such as the Financial Action Task Force on Money Laundering (“FATF”).

Any Client who gives the Compliance Officer any reason to believe that its funds originate from, or are routed through, an account maintained at an ‘offshore bank,’ or a bank organized or chartered under the laws of a Non-Cooperative Jurisdiction; and

Any Client who gives the Compliance Officer any reason to believe that the source of its funds may not be legitimate or may aid terrorist activities.

Non-cooperative Jurisdiction may also be the cause of rejecting cooperation with a client that is associated with a non-cooperative jurisdiction. These jurisdictions are: United States New York (NY) Georgia (GA) Connecticut (CT) New Mexico (NM) Washington (WA) Hawaii (HI) Afghanistan Bosnia and Herzegovina Cuba Ethiopia Iran Iraq Democratic People’s Republic of Korea Lao People’s Democratic Republic Sri Lanka Sudan Syrian Arab Republic Trinidad and Tobago Tunisia Uganda

Vanuatu Yemen Lebanon Serbia Algeria Bangladesh Bolivia Cambodia China Kyrgyzstan Macedonia Nepal Nigeria Thailand Russia Belarus

On top of all the required documentation related to natural person identification through simplified or basic due diligence procedures, enhanced due diligence procedure includes but is not limited to such measures:

Assessing the Client’s business reputation through review of financial or professional references, generally available media reports, or by other means;

Considering the source of the Client’s wealth, including the economic activities that generated the Client’s wealth and the source of the particular funds intended to be used to make the investment;

Reviewing generally available public information, such as media reports, to determine whether the Client has been the subject of any criminal or civil enforcement action based on violations of anti-money laundering laws or regulations or any investigation, indictment, conviction, or civil enforcement action relating to financing of terrorists;

Conducting a face-to-face meeting with the Client to discuss/confirm the account opening documents.

Reviewing recent changes in the ownership or senior management of the Client;

Conducting a visit to the Client’s place of business and conducting a face-to-face meeting with the Client to discuss/confirm the account application, the purpose of the account, and the source of assets.

The Company’s compliance officer is always entitled to ask any High-Risk Client for additional documentation to complete proper KYC/AML procedure and if there are any suspicions on money laundering or dishonest activities. The Company is entitled to stop any cooperation with the client or not to enter it if the client failed to refute any suspicions. The Company is entitled to report any unlawful activity.

Genesis requires providing the User for the KYC process depending on the Account type chosen by the User.

Natural person For the Basic Account, the User, who is a natural person, is required to provide at least:

Selfie or live verification identity document;

Proof of address document.

For the Pro Account, the User, who is a natural person, is required to provide at least:

Selfie or live verification identity document;

Proof of address document (not older than 90 days);

Source of funds declaration and document, confirming the source of funds.

Live video verification

Selfie with wording, confirming the client’s name, date and wallet number.

Transaction identification requirements The Company is entitled to ask for any documents required for AML/KYC procedure. The list of documentation may change depending on the sums of the transaction. Please pay attention that the Client is obliged to provide all the documents requested by the Company.

Updates to the KYC Policy The KYC policy may be amended/updated according to the current and effective legislation and international regulations.