Adara Anti-Money
Laundering Policy
Version 1.1
Last Updated on 24th May 2018
Introduction
  1. This Anti-Money Laundering Policy (“AML Policy”) relates to the website https://adara.io/ and/or any sub-website and/or associated domains (and/or sub-domains) of https://adara.io/ (hereinafter referred to as the “Site” owned by Kyon Ltd, “We”, “Us”, “Our”, “Ourselves” and/or “Kyon” shall refer to Kyon Limited (C 89188) and “You” and “Your” and “User”refer to prevent and mitigate possible risks of Site being involved in any kind of illegal activity. Both international and local regulations require Site to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
  2. Our full details, including contact details, can be read below.
Verification procedures
  1. One of the international standards for preventing illegal activity is customer due diligence. According to customer due diligence, Site establishes its own verification procedures within the standards of anti-money laundering framework.
  2. Site identity verification procedure requires the User to provide Us with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes We reserve the right to collect User’s identification information for the AML Policy purposes.
  3. We will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and We reserve the right to investigate certain Users who have been determined to be risky or suspicious.
  4. We reserve the right to verify User’s identity in an on-going basis, especially when their activity seemed to be suspicious (unusual for the particular User). In addition, We reserve the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
  5. User’s identification information will be collected, stored, shared and protected strictly in accordance with the Our Privacy Policy and related regulations.
  6. Once the User’s identity has been verified, We are able to remove Ourselves from potential legal liability in a situation where its Services are used to conduct illegal activity.
Anti-money laundering policy
  1. We enforce a strict anti-money laundering policy with zero tolerance for money laundering activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.
  2. All Our affiliates are obligated to comply with Ours anti-money laundering policy and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.
  3. We ensure complete compliance with laws pertaining to anti money laundering through its related policy.
  4. We implement a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operations throughout the Site.
  5. Activities that We consider possible indications of money laundering include:
    • The client showing unusual apprehension or reservations about Ours anti-money laundering policies.
    • The client’s interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the client’s business policy.
    • The client failing to provide legitimate sources for their funds.
    • The client providing false information regarding the source of their funds.
    • The client having a history of being the subject of news that is indicative of civil or criminal violations.
    • The client seems to be acting as a ‘front man’ for an unrevealed personality or business, and does not satisfactorily respond to requests for identifying this personality or business.
    • The client not being able to easily describe the nature of his/her industry.
    • The client frequently makes large deposits and demands dealing in cash equivalents only.
    • The client maintains multiple accounts and conducts an unusually high number of inter-account or 3rd party transactions.
    • The client’s previously usually inactive account starts receiving a surge of wire activity.
The above list is by no means an exhaustive list. We monitor ours client and account activity in light of several other red flags and takes appropriate measures to prevent money laundering.
Company details
  1. Kyon Ltd is a company registered in Malta with company registration number C 89188 and whose registered office address is at 136, St. Christopher’s Street, Valletta.
  2. If You have any questions/ comments about Our AML policy, please contact Us at: info@adara.io or by writing to Kyon Limited, 136, St. Christopher’s Street, Valletta, Malta.
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