AML/KYC Policy

Last updated: 11.11.2024

1. Introduction

   At NORD (the "Company", "we", "us" or "our") we are committed to complying with applicable anti-money laundering (AML) regulations and know your customer (KYC) procedures to prevent illegal activities, including money laundering, terrorist financing, and other financial crimes. This AML/KYC Policy describes the measures we take to ensure compliance with these requirements and maintain the integrity of our Services.

   By using our Services, you agree to comply with this Policy.

2. Purpose of the Policy

   The purpose of this AML/KYC Policy is to:

• Verify the identity of our users.

• Detect and prevent suspicious activity.

• Ensure compliance with applicable laws and regulations.

• Protect the Company and its users from financial crimes.

3. Legal Basis

   This Policy is developed in accordance with the AML and KYC requirements established by competent authorities in the jurisdictions where we operate, including:

• International standards developed by the Financial Action Task Force (FATF).

• National laws and regulations of Georgia.

4. Customer Identification Program (CIP)

   We have implemented a robust Customer Identification Program to verify the identity of our users. This includes:

4.1 Required Information

• Full legal name.

• Date of birth (for individuals).

• Residential address or business registration address.

• Government-issued identification (e.g., passport, national ID, driver's license).

• Additional documents or information as needed (e.g., utility bills, proof of income).

4.2 Verification Methods

• Manual review of the provided documents.

• Use of third-party tools or databases for verification.

• Biometric verification, where possible.

5. Risk-Based Approach (RBA)

   We apply a risk-based approach to identify and manage risks associated with money laundering and terrorist financing. As part of this approach, we:

• Classify users by risk levels — low, medium, high — based on predetermined criteria.

• Conduct enhanced due diligence (EDD) for high-risk users.

• Monitor transactions for unusual or suspicious patterns.

  
  

6. Monitoring and Reporting

   We continuously monitor user activity and transactions to identify suspicious activity. In particular, we:

• Identify transactions exceeding established thresholds or having unusual characteristics.

• Investigate and report suspicious activity to appropriate authorities.

• Maintain records of transactions and reports for the legally required retention period.

7. Enhanced Due Diligence (EDD)

   For users or transactions with a high-risk level, we may require additional verification, including:

• Documents verifying the source of funds or wealth.

• Additional forms of identification.

• In-person interviews or video calls.

8. Sanctions Screening

   We conduct regular checks to ensure that users are not included in international sanctions lists, including:

• United Nations Security Council sanctions list.

• Lists maintained by OFAC, the EU, and other regulatory bodies.

  Users found on such lists may be restricted from accessing our Services or have their accounts terminated.

9. Data Privacy and Security

   We are committed to protecting personal data collected as part of the AML/KYC procedures. All data:

• Is collected and processed in accordance with data protection laws, including GDPR (if applicable).

• Is securely stored to prevent unauthorized access, use, or disclosure.

10. User Obligations

    By using our Services, you agree to:

• Provide accurate and reliable information during the KYC process.

• Update your information whenever changes occur.

• Refrain from engaging in prohibited activities, such as money laundering or fraud.

11. Consequences of Non-Compliance

    Violation of this Policy may result in:

• Suspension or termination of your account.

• Reporting your activities to the appropriate regulatory or law enforcement authorities.

12. Training and Awareness

    Our employees and relevant personnel receive regular training on AML/KYC policies and procedures to ensure their effective implementation and compliance.

13. Policy Updates

    We reserve the right to make changes to this AML/KYC Policy at any time to reflect changes in legislation, regulatory requirements, or improvements to our processes. New versions take effect immediately upon publication.

14. Contact Information

    If you have any questions regarding this Policy or need assistance with the KYC process, please contact us:

    Email: inbox@nord.international

15. Confirmation of Acknowledgment

    By using our Services, you confirm that you have read, understood, and agree to comply with this AML/KYC Policy.