AML Policy

GreenElephant OÜ

License Number FVT000066

A. Anti-money Laundering

This policy is to establish guidelines for GreenElephant OÜ (“Company”, “GreenElephant” “We”, “US”), Estonia FIU License Number FVT000066, ‘Anti-Money Laundering’ and ‘Know Your Client’ (“KYC”) procedures for new and existing clients.

All of monetary transactions, to the best knowledge of the Company shall be free from any form of money laundering and terrorist activities. The Company operates with integrity and is committed to implementing the measures established. The Client’s failure to comply with the regulations set by the Company would mean termination of the account. If the Client is proven of committing money laundering, he is responsible for any damage or loss which may occur, and the Company is excluded from his fraudulent actions.

In an effort to counter money laundering and other illegal activity, we have decided not to support any cash transactions, regardless of their stated purpose. We have the right to cancel or deny a transaction at any point if there are suspicions regarding its legality.

We reserve the right to not encounter in any kind of relations with the client upon our sole decision.

GreenElephant has the obligation in order to counter any form of money laundering and terrorist activities to report the relevant authorities and bodies about suspicious activities of its clients.

General Measures

It is the Company’s AML Policy to apply to all clients the below mentioned general measures:

check the identity of the Client and proof the authenticity of the provided KYC and documents.
monitor any suspicious Client activities and/or transactions and report them;
have a record of all the related information and/or documents of the Client’s financial transactions.

The Company’s KYC and due diligence procedures are applied by the Company’s Back Office and Compliance departments when accepting clients to open exchange accounts with the GreenElephant.

Restricted Business and Jurisdictions

GreenElephant does not provide services to clients that their activities are associated with any high risk or banned activities. We do not enter into any relations with the natural personas or legal entities directly or indirectly dealing with the following black-listed activities:

Alcoholic beverages;
Child abuse imagery and child pornography;
Counterfeit products and replicas;
Fireworks or pyrotechnic devices or supplies and other related items;
Drugs and drugs trafficking;
Hazardous materials, combustibles, corrosives;
Human trafficking, Human Body Parts, Fluids and remains;
Illegal products or services;
Illegal substances and products, online pharmacies or pharmacy referral services;
Jail breaker equipment and software, hacking and cracking materials;
Merchants involved with bestiality, rape, hate, violence, or incest;
Portrays of religious or cultural symbols in a manner construed as offensive or unacceptable;
Promotion of hatred, racism, religious persecution or the initiation of force against others;
Sales of cultural artefacts;
Substances designated to mimic illegal drugs;
Weapons and munitions, fire arms, ammunition, high capacity magazines, teasers, air gun;
Any product or service that infringes upon the copyright, trademark or trade secrets of any third party;
Essay mills, unauthorized copyright media and software, academic fraud;
Flea markets;
Personal computer technical support, products and services designated to deliver unsolicited electronic communications, spy-ware, spam-ware, malware, services or features not paid for (circumvent locks, programming codes, etc.), satellite signal decoding products, cards and card programming;
Shipping or forwarding brokers, future order fulfillments beyond three months;
Chain letters;
Charities and umbrella organizations that receive money of charities;
Crowdfunding platforms;
Firms selling business opportunities, investment opportunities, mortgage consulting or reduction, credit counselling, repair or protection, or real estate purchases with no money down;
Marketing, predatory or deceptive activities including but not limited to door-to-door sales, offering substantial rebates or special incentives to the payers subsequent to the original purchase, negative response marketing, engaging in deceptive marketing practices, sharing consumer information with another merchant for payments of up-sell or cross-sell product or service, engaging in any form of licensed or unlicensed aggregation or factoring, extended warranties, telemarketing;
Multi-level marketing or pyramid schemes;
Pawn shops;
Funding any of the items included on this Prohibited Business List.

The following activities are subject to enhanced due diligence and compliance check:

Gambling;
Brokers;
Sports forecasting or odds making;
Adult;
Intermediary merchant services;
Online gaming, in-game items.

GreenElephant reserves the right reject your application upon sole decision if out Compliance department considers your business exceeding our risk policy.

We have the right to update our list of blocked and enhanced due diligence activities from time to time.

Furthermore, the Company does not accept clients from high risk countries, including but not limited to the following countries:

Afghanistan
Albania
Algeria
American Samoa
Bahamas
Barbados
Bangladesh
Bolivia
Bosnia and Herzegovina
Botswana
Brazil
Cambodia
China
Colombia
Congo
Cuba
Democratic People’s Republic of Korea
Ecuador
Ethiopia
Ghana
Guam
Indonesia
Iran
Iraq
Jamaica
Japan
Jordan
Kyrgyzstan
Laos
Lebanon
Libya
Mauritius
Mongolia
Morocco
Myanmar
Nepal
Nicaragua
Nigeria
North Macedonia
Occupied Palestinian Territory
Pakistan
Panama
Puerto Rico
Samoa
Serbia
Somalia
Sri Lanka
Sudan
Syria
Taiwan
Trinidad and Tobago
Tunisia
Uganda
USA
US Virgin Islands
Vanuatu
Venezuela
Vietnam
Yemen
Zimbabwe

Furthermore, the Company does not accept clients from high-risk countries as per the guidelines of FATF http://www.fatf-gafi.org/countries/ which is updated accordingly.

Jurisdictions requiring enhanced due diligence:

Iceland
Macau
Malaysia
Thailand

We have the right to update our list of blocked and enhanced due diligence jurisdictions from time to time.

B. Know Your Customer (KYC) Procedure

The KYC procedure is a requirement in order to comply with the International law provisions, including the ones designed to prevent money laundering. The following should be followed unless an amendment is sent from the Compliance Department stating otherwise.

When a client applies to open an account with us it is the Company’s duty to ensure that along with the application the following documents are received:

Natural Persons – (this also applies to natural persons involved in a legal entity such as Directors, Shareholders or authorized persons)

1. Proof of Identity (POI)

Is any document which may be used to prove a person’s identity. It should be valid and expire not sooner than in 6 (six) month from the date of client’s application for services. All the data shall be clear and readable. All the sides, MRZ lines and corners of the documents shall be clearly visible. For European citizens, an Identification card is sufficient. For all other’s it should be a passport. In the absence of the passport, the identification with a driving license plus additional identification document will be accepted instead.

2. Proof of Residence (POR)

A proof of residence is a document confirming where the client lives. It needs to have both the name of the individual and his/her address printed on it. The document shall not be older than 3 (three month) issued from the date of the application for services. Such documents are: Recent Utility Bill. This can be water bill, electricity bill, bank statement or bank reference letter, tax bill, municipality bill where home address is shown or

Bank Statement or
Local Authority Tax Bill or
Any other official document same with the abovementioned.

Mobile phone bill, insurance statement, electronically generated documents are not accepted.

3. Proof of Bank Account Ownership OR Credit card data depending on the case.

If a new client wishes to exchange Cryptocurrency to FIAT, he must also provide proof of ownership of account. Such document is a bank statement where the name and the address match the company’s records

Most common question regarding documents requirements can be found at FAQ section.

Corporate Accounts

When a legal entity wishes to open an account with GreenElphant OÜ the below must be collected:

Company’s Incorporation Documents

Certificate of incorporation or equivalent
Certificate of registered office or equivalent
Certificate of directors and secretary or equivalent
Certificate of shareholders or equivalent
Memorandum and articles of association of the legal person
Recent copy (up to three months) of a bank statement or utility bill in order to verify the head office address
Identity of Directors and Shareholders with their relevant KYC documents required of Natural Persons
Authorized person resolution signed by the Board of directors (‘BoD’)

Additional Documents

Depending on the amount the client wishes to exchange, the Company has formed Check cases where the required documentation differ. These Check cases are:

Check case 1

Up to EUR 10,000

Check case 2

Above EUR 10,001

PoR
PoI
Proof of source of funds

Recordkeeping

Assessment of client documents will be made on an annual basis. All client’s documents and record transactions will be kept safely and back-up for a minimum five (5) year period.

C. Transfer of funds

General Practice

When transferring money for purchasing digital currency, the sender’s name and the information held on file, should match.

Money transfers from another party other than the account holder is strictly prohibited.

Furthermore, we will refuse any third-party transfers towards one of our Clients.

In case there is any discrepancy on a transaction, we reserve the right to automatically cancel or suspend the transaction. Further to this, third parties are forbidden to conduct the transaction in replace of the Client.

D. REFUNDS AND CHARGEBACKS

For the terms of providing the refund please see Company’s [Refund Policy]

While we are taking appropriate measures to avoid chargebacks, in may be inevitable that we may have chargebacks, therefore the Company will take the relevant actions to avoid such issues. In such cases, the Company applies the following to all of its clients prior to execute/complete client’s order:

KYC documentation collected as per guidelines
Name of the cardholder matches with the account holder with our platform
Client confirmed and accepted all policies such as “Risk policy”, “Terms and Conditions” found on the website during the registration stage

For any possible claims against the Company, each case will be evaluated in detail and if found that all procedures were followed correctly as per requirements, the Company will challenge any chargeback that may arise.

Important Notes

We reserve the right to request from each client to conduct the remote verification with help of external providers for online KYC verification, identity verification and person check for the purpose of ensuring that the person is not Politically Exposed Person (PEP) or person associated with the PEP etc.
Where the documents provided for the compliance check are not in English we require an official translation from the sworn translator, court translator, certified notary or advocate etc confirming the authentity of the document, it’s content and translation.
We reserve the right to request certified, notarized, apostilled documents from any client despite the fact the client is a natural or legal person.
We reserve the right to request additional documentation upon our sole decision or decision of our partners and third parties involved into provision of GreenElephant OU services for the compliance purposes.

GreenElephant OÜ has the right to refuse any client without giving reason.

These guidelines have been implemented to protect GreenElephant OÜ and its clients.