AML (Anti-Money Laundering) and KYC (Know Your
Customer) Policy of Denistiaglin.com
The objective of the Anti-Money Laundering and Know-Your-Customer Policy (сAML &
KYC Policy») is to prevent money laundering and terrorist financing activity on the Website by
meeting the international and domestic legislation requirements and implementation of
identification procedure of users
According to the AML & KYC Policy, «Denistiaglin.com», «Company», «we», «us» or
«our» refers to the Limited Liability Company «WETER LLC», located at 630099, Novosibirsk
region, Novosibirsk, Deputatskaya str., 1, office 100 , including, without limitations, its owners,
directors, investors, employees and other related persons. Depending upon the context,
«Denistiaglin.com» may also refer to the services, products, website, content or other materials
provided by Denistiaglin.com.
Capitalised terms used in this Anti-Fraud Policy have the following meaning:
Prohibited Conduct means any illicit conduct that includes fraud, corruption, money
laundering, collusion, terrorist financing and any other criminal conduct.
Fraud means use of deception with the intention of pursuing personal interests and causing
loss to the proper interests of Users and/or Denistiaglin.com.
Corruption means offering, giving, receiving, or soliciting, directly or indirectly, anything of
value to influence improperly the action of another party.
Money laundering means a financial transaction scheme that aims to conceal the identity,
source, and destination of illicitly-obtained money.
Collusion means arrangement between two or more parties designed to achieve an improper
purpose, including influencing improperly the actions of another party.
Terrorist financing means provision or collection of funds, by any means, directly or
indirectly, with the intention that they should be used or in the knowledge that they are to be used,
in full or in part, in order to carry out any of the offences on combating terrorism.
Criminal conduct means an offence in any part of the world or would constitute an offence
in any part of the world if it occurred there.
Capitalised terms not defined in this Anti-Fraud Policy have the meaning as they defined in
the Terms of Service.
The company shall comply with the requirements contained in the local and internaional
Acts on Prevention of Money Laundering and Terrorism Financing, as well as the
requirements of other laws and regulations to the extent in which they relate to the
Company's operations, including but not limited to the following practices:
Collecting information about Customers.
Create and update internal policies and procedures as required by applicable laws
Providing law enforcement authorities with the information required under applicable
Monitor transactions and investigate any significant deviations from normal
The company develops this AML & KYC Policy, may introduce amendments and
additions to it at its own discretion, and will oversee compliance with its provisions and
requirements. The Company reserves the right to:
Request any additional information and documents from the Customer in case of
Suspend or terminate the operation of the Client's trading account, if the Company has
reasons to believe that the Client is involved in illegal activities.
The current version of the Policy is always available on the website at:
AML & KYC policy includes customer verification procedure, monitoring of
customer transactions as well as assessment of possible risks.
Client verification procedure includes identification of the person, for the
implementation of which the Company requires to provide documents, data or information
(e.g. national ID card and international passport).
The Company will take steps to confirm the authenticity of documents and information
provided by the Client. The Company reserves the right to verify the Client's identity on an
ongoing basis, especially when his identification information has been changed or his
activities are suspicious.
The Company reserves the right to request from the Client up-to-date documents even if
they have been authenticated earlier.
«Know Your Customer» Verification Procedures
The Company conducts the Know Your Customer (KYC) verification procedures to
avoid the risk of being held liable and to protect itself from a Customer's attempting to use
the Company for carrying out illegal activities.
As part of the KYC procedures, the Company evaluates Customers' transactions, as well
as collects and stores information on the essential facts pertaining to Customers, potential
Customers, and their transactions.
After carrying out the identification procedures pertaining to a Customer, the Company
stores the information obtained in this Customer's file. The Company is under obligation to
carry out the identification procedures pertaining to a Customer once.
The company is committed to protecting Customers' rights and the confidentiality of
their personal data. The Company collects personal information from Customers only to the
extent necessary to ensure the Company's properly providing services to Customers. Such
personal information about Customers and former Customers may be disclosed to third
parties only in a limited number of circumstances, in accordance with the applicable laws
and agreements between the Company and the Customer.
The company shall carefully maintain Customers' files, including statements,
transaction reports, receipts, notes, internal correspondence, and any other documents
related to the customer in electronic format for as long as may be required by the
underwriting teams at the relevant acquiring banks / processors that the Customer makes use
The Company has the right to suspend the Account that is involved in suspicious
activity and request the owner of such Account to pass the KYC procedure.
Identification and Detection of Suspicious Activities
Any financial transaction that may be related to money laundering activities shall be
considered to be suspicious activities
Grounds for determining that a specific transaction is suspicious may be personal
observations and experience of the Company's employees, as well as information received
The Merchant Services Officer shall continuously monitor and update the systems used
by the Company to detect suspicious activities
In accordance with the applicable laws and the requirements of international
organizations, the Company may, where appropriate and without the obligation of obtaining
the Customer's approval or notifying the Customer, notify regulating and/or law
enforcement agencies of any suspicious transactions.
The Company shall periodically refer to and consult the lists published by the local
authorities and international organizations that contain lists of known terrorists or persons
suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of
countries subject to the OFAC sanctions, jurisdictions that do not provide sufficient level of
anti-money laundering procedures, as well as countries subject to sanctions to determine
whether the Company's Customer or potential Customer, and/or such Customer's country of
jurisdiction is included in the above lists.
The Company shall continuously conduct due diligence procedures pertaining to its
Customers and scrutinize transactions carried out by them to ensure these transactions'
compatibility with the Company's knowledge of its Customers, their business and, when
necessary, their source of funds.
This document has been developed to mitigate financial and legal risks, in compliance
with the Anti-Money Laundering Policy and the «Know Your Customer» Policy («AML &
Company WETER LLC has the right to unilaterally block the login to the Personal
Office, suspend trading activity on accounts, cancel the deposit/withdrawal application or
refund funds if the source of funds or the Client's activity contradicts the money laundering
and terrorist financing policy
In case the Company classifies the source of funds or the activity of the Client as
inconsistent or contrary to the admissible purposes of using the services of the Company, in
which the direct or indirect, improper or unfair intentions can be seen, the Company has the
right to act within the framework of this document, without informing the Client about it in
The Company has the right, at its own discretion, to return the provided investments to
the sender within one year from the receipt of funds in accordance with the Investment
The Company has the right, if necessary, to return money received through any payment
system, including credit and/or debit cards. In this case, the refund will be made to the same
account from which the payment was made.
After the Client has made the targeted funding by making an investment through any
payment system, including credit/debit cards, the Client agrees not to request a refund in any
way, except by directly contacting the representatives of the Company. In case the Client
makes such a request for a refund in a bank or payment system, the Company reserves the
right to block the Client's login to the Client's personal account, freeze the current balance of
the Client and return funds to the Client after deduction of the amounts of all services and
commissions payable by the Client
The Company will take all necessary measures to prevent and block both unauthorized
deposit and withdrawal of funds from the Client's account by third parties
Deposit and return of investments can be made only by the Client from his account,
except when a copy of the application from a third party with the authorization to deposit the
Client's account from his account (e-wallet, bank card) is submitted
At the same time, the application must be handwritten and signed by such third party.
The third party shall be fully verified as a client of the Company. The Company, at its own
discretion, has the right to refuse such deposit operation to the Client
Amendments and modifications
This KYC Policy may be modified or amended at any time, at the sole discretion of
Denistiaglin.com. You acknowledge and agree that it is your own responsibility to review
the KYC Policy periodically and become aware of amendments and modifications.
If you do not wish to accept the modified and/or amended KYC Policy, you should not
continue to use the Service. Your continued use of the Site and/or the Service following the
posting of changes to the KYC Policy will be deemed as your acceptance of those changes.