Cronheim Larsson UK LTD’s ("WeSellCrypto" or the "Company") Anti-Money Laundering ("AML") Policy, OFAC Policy, and Identity Verification Policy (collectively the "AML Policy") is designed to articulate WeSellCrypto’s commitment to detecting, preventing, and reporting attempts to use its financial services platform to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, or to commit fraud.
Money laundering is the illegal practice of "cleaning" criminally derived (or "dirty") funds through a series of transactions so that they appear to be proceeds from legal activities or constitute legitimate assets. Although money laundering is a diverse and often complex process, it generally involves three independent steps that can occur separately or simultaneously: (1) Placement, (2) Layering, and (3) Integration.
In a related but different context, terrorist financing may not involve the proceeds of criminal conduct, but may entail an attempt to conceal the origin of the funds or their intended use. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.
WeSellCrypto is committed to comply with applicable regulations to prevent money laundering. These regulations include, but are not limited to:
As such, WeSellCrypto has defined the following pillars for compliance:
Regulations also require MSBs to monitor for suspicious activity and to file Suspicious Activity Reports ("SARs"). The purpose of the SAR is to report known or suspected violations of law. As part of its adherence to regulatory requirements, MSBs must file SARs with the relevant government authorities as appropriate.
Sanctions generally fall into two categories: (1) sanctions that prevent entities from doing business with, or moving assets in and out of, particular countries (e.g., North Korea or Cuba) and (2) sanctions that prevent entities from doing business with, or moving assets to and from, specific people (e.g., named druglords). WeSellCrypto screens against United Nations, European Union, United States and United Kingdom Treasury sanctions list in all jurisdictions in which it operates
This Policy (1) explains WeSellCrypto's Service and articulates WeSellCrypto's policy regarding AML and Identity Verification, (2) designates the WeSellCrypto personnel responsible for implementing this Policy and explains their role in its implementation, and (3) describes the WeSellCrypto Anti-Money Laundering, Sanctions Compliance, and Identity Verification Program ("AML Program"), which is designed to operationalize this Policy. The Policy and AML Program apply to all of WeSellCrypto’s personnel and business activities
WeSellCrypto offers virtual currency purchase services to its customers through www.wesellcrypto.com (the "Service"). The Service allows people to purchase decentralized virtual currency from WeSellCrypto, such as Bitcoin, Dogecoin, and Litecoin.
WeSellCrypto recognizes that decentralized virtual currency systems in which payments are processed and secured by advanced cryptography and distributed computing power instead of a central bank, corporation, or government may pose certain unique risks of illegal uses (as do all financial systems). Accordingly, WeSellCrypto has implemented this Policy and its accompanying AML Program to assess the specific risks posed by WeSellCrypto's Service and established specific controls to address those risks as required by law.
It is WeSellCrypto's policy to comply with applicable laws and regulations regarding AML and identity verification, and to detect and prevent the use of its Service for money laundering, committing or perpetuating identity theft, or facilitating criminal or terrorist activities. While WeSellCrypto is committed to protecting its users' privacy, it will not knowingly allow people to use its Service to launder money, to commit fraud or other financial crimes, to finance terrorist activities, or to facilitate other illegal conduct.
All employees are responsible for understanding this Policy and undertaking any specific AML responsibilities assigned to them.
WeSellCrypto's AML Compliance Officer directs, implements, enforces, maintains, and updates the WeSellCrypto AML Program. The AML Compliance Officer is appointed by the members of WeSellCrypto ("Members"), is a senior employee of WeSellCrypto, and is authorized to make decisions for the Company regarding compliance with this Policy, the AML Program, and applicable laws and regulations addressing AML, fraud, financial crimes, financing of terrorist activities, and other illegal conduct.
The AML Compliance Officer is also responsible for reporting to WeSellCrypto executives and senior management regarding the AML Program; for serving as the Company's primary point of contact with governmental entities regarding the AML Program; and for serving as the company's primary point of contact within WeSellCrypto itself and between WeSellCrypto and its subcontractors, agents, service providers, customers, and partners regarding the WeSellCrypto AML Program.
Notwithstanding the delegation of the day-to-day activities of AML compliance to the AML Compliance Officer, the Members remain responsible for ensuring that adequate staff and resources are available for the AML Compliance Officer to execute the duties of this Policy and the associated Program and its related procedures, and for ensuring that the Company’s AML Program is effective.
WeSellCrypto’s current AML Compliance Officer is Greg Cronheim.
All WeSellCrypto employees are responsible for (1) reviewing and understanding the AML Program; (2) helping to detect and prevent the use of the Service for money laundering, fraud or financial crimes, the financing of terrorist activities, or other illegal conduct as provided in the Program and Compliance Controls; (3) attending required training and education programming regarding the WeSellCrypto AML Program; and (4) helping to ensure ongoing compliance with the AML Program.
WeSellCrypto implements this AML Policy through its AML Program, which contains six sets of controls: (1) registration and relationships; (2) identification, verification, and screening; (3) monitoring, reporting, and information disclosures; (4) recordkeeping; (5) training and education; and (6) compliance monitoring and program updates.
At least annually, the AML Compliance Officer reviews this Policy and the AML Program and recommends any appropriate changes for approval by the WeSellCrypto Members. The review includes consideration of applicable law, feedback on the effectiveness of the Policy and AML Program, and any supervisory or audit input.
No part of this Policy or the AML Program should be interpreted as contravening or superseding other legal and regulatory requirements imposed upon the Company. Any conflicts between this Policy, or the AML Program, and the Company’s other legal obligations must be submitted immediately to the AML Compliance Officer for further evaluation. If necessary, the AML Compliance Officer will consult outside legal counsel to ensure that this Policy and the associated AML Program is current with all applicable laws and regulations.
All exceptions to this Policy or the AML Program must be approved in writing by the AML Compliance Officer.
Questions or suggestions about this Policy or the AML Program should be sent to the AML Compliance Officer.