Anti-Money Laundering and Know Your Customer Policy
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Last updated July 30, 2023
Jobajuba Digital Studio (hereinafter – Yumpie Token”) Anti-Money Laundering and Know Your Customer Policy (hereinafter – “AML and KYC Policy”) is designated to prevent and mitigate possible risks of Yumpie Token being involved in any kind of illegal activity.
Both international and local regulations require Yumpie Token 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.
This AML and KYC Policy applies to both natural and legal persons. Legal entities joining the Yumpie Token ICO, which is defined as making a Yumpie Token purchase in a specific method stated in the clause 4 of this AML and KYC Policy will receive purchased tokens to their ERC-20 address after required AML and KYC procedures that include providing specific documents.
AML and KYC Policy covers the following matters:
Verification procedures.
1.1. Basis
1.2. Identity verification
1.3. Anti-money laundering procedure
1.4. Authenticity verification
1.5. Right to report
1.6. Continuous basis of information verification
1.7. Transaction proceed refusal
1.8. Payment cancellation
Compliance Officer.
2.1. Definition
2.2. Duties
2.3. Law enforcement
Monitoring Transactions.
3.1. Data analysis
3.2. Suspicious transactions reporting
Payment methods
4.1. Coinbase, Metamask, payment cards
4.2. Payment cards usage control
4.3. Coinbase and Metamask transfer control
4.4. Address analysis
4.5. Liability
4.6. Due diligence
Risk Assessment.
AML and KYC Policy
6.1. Acceptance
6.2. Privacy Policy
1. Verification procedures.​
1.1. Basis​
One of the international standards for the prevention of illegal activities is Know Your Customer (“KYC”). According to the KYC, Yumpie Token establishes its own verification procedures within the framework of anti-money laundering standards and Know Your Customer.
1.2. Identity verification​
Yumpie Token’s identity verification procedure requires the User to provide reliable independent sources of documents, data or information (e.g. ID card, international passport, bank statement, utility bills) every time the User is requested to provide certain information. For AML and KYC Policy purposes, Yumpie Token hereby reserves the right to collect User information.
1.3. Anti-money laundering procedure​
Yumpie Token’s anti-money laundering procedure requires the User to provide information about the source of the funds the User uses to purchase Yumpie Token tokens every time the User is requested to provide certain information. Yumpie Token is not responsible for any errors or omissions in the information provided by the User.
1.4. Authenticity verification​
Yumpie Token shall take steps to verify the authenticity of documents and information provided by Users, use all legal methods to double-check identification information and hereby reserves the right to investigate the actions of certain Users that have been found risky or suspicious.
1.5. Right to report​
We may therefore report our suspicions regarding any activity of the users to local regulators, enforcement bodies and other compliance bodies. Those kind of actions have a goal of ensuring that the capital being used on our platform has a legitimate origin and create a safeguard in case of individuals or groups wanting to allocate their money from illegal activities on our platform.
1.6. Continuous basis of information verification​
Yumpie Token hereby reserves the right to verify the User’s identity on a continuous basis, especially when the verification information has been changed or the User’s activity has been deemed suspicious, even if they have already undergone identity verification. User verification information shall be collected, stored, transferred and protected strictly in accordance with Yumpie Token’s Data Protection Policy and the relevant rules. Following the verification of User’s identity, Yumpie Token disclaims potential legal liability in situations where its Services are used for illegal activities.
1.7. Transaction proceed refusal​
Yumpie Token may refuse to proceed the transaction of transferring the purchased tokens to the User if the User refuses to provide any demanded information. Yumpie Token may refuse to issue tokens to the User if:
a. The User does not provide any demanded information to Yumpie Token and enables to complete any diligence procedures on the User;
b. The User have been previously identified as engaged in suspicious activity;
c. The User is the citizen of a country considered to be exposed to a high risk of money laundering or financing terrorism;
d. The User is listed on a sanctions list in any of the jurisdictions to which Yumpie Token may transfer purchased tokens, or Yumpie Token otherwise identifies the User as exposed to a high risk of money laundering or financing terrorism.
1.8. Payment cancellation.​
The User cannot cancel a request to purchase the tokens. Yumpie Token may cancel the User’s purchase of the tokens if it is impossible to verify User’s identity or conduct any other procedures that Yumpie Token is required to conduct. Yumpie Token may not refund User any amount until the User has provided any demanded information required by law.
2. Compliance Officer​
2.1 Definition​
The Compliance Officer is the person, duly authorized by Yumpie Token, whose duty is to ensure the effective implementation and enforcement of the AML and KYC Policy.
2.2 Duties​
It is the Compliance Officer’s responsibility to supervise all aspects of Yumpie Token’s anti-money laundering and counter-terrorist financing, including but not limited to:
a. CollectingUser’sidentificationinformation;
b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
c. Monitoring transactions and investigating any significant deviations from normal activity;
d. Implementing a record management system for appropriate storage and retrieval of documents, files, forms and logs;
e. Updatingriskassessmentregularly;
f. Providing law enforcement with information as required under the applicable laws and regulations.
2.3 Law enforcement​
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
2.4 Contact with the clients and authorities​
The Compliance Officer is obliged to communicate effectively with the clients and authorities having any complaints or questions that are being addressed to him/her regarding the Yumpie Token AML and KYC Policy as also its implementation in order to ensure the transparency and credibility of the platform. The address to contact the Compliance Officer is compliance@yumpie.com or support@yumpie.com. Any kind of correspondence sent to the Compliance Officer will be addressed by him within the time frame of 5 working days.
3. Monitoring transactions​
3.1 Data analysis​
User verification is carried out not only by checking their identity, but also by analyzing transaction models. Yumpie Token therefore relies on data analysis as a tool for assessing risk and identifying suspicions. Yumpie Token carries out many regulatory compliance tasks, including data collection, filtering and record keeping.
3.2 Suspicious transactions reporting​
With regard to the AML and KYC Policy, Yumpie Token will monitor all transactions, and it reserves the right to ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer and request the User to provide any additional information and documents in case of suspicious transactions. Compliance Officer will monitor User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Payment methods​
4.1 Coinbase Commerce, Metamask, Payment Card, ETH Direct Deposit or Wire transfer​
The User may purchase Yumpie Token tokens by linking the Metamask wallet and managing the Ethereum deposit, transferring any cryptocurrency by Coinbase Commerce, or by card or wire transfer. To carry out a transaction in a chosen way, the User must follow the relevant instructions on the Yumpie Token site.
4.2 Payment cards usage control​
Yumpie Token may refuse to complete or block, cancel or reverse a transaction of the Yumpie Token token purchase made with payment cards usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action. Yumpie Token is under no obligation to disclose the details of its credit card risk management and security procedures to the User.
4.3 Coinbase Commerce and Metamask transfer control​
Yumpie Token may refuse to complete or block, cancel or reverse a transaction of the Yumpie Token token purchase made with Coinbase (Coinbase, Inc. 100 Pine Street, Suite 1250, San Francisco, CA 94111) or Metamask (MetaMask c/o ConsenSys, 49 Bogart Street, Brooklyn NY 11206) usage if the User is suspected of money laundering, terrorist financing, fraud, any other financial crime, or any other illegal action.
4.4 Address analysis​
Yumpie Token may analyze the cryptocurrency addresses against common blacklists and known security discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money laundering (location, layers, integration), either manually or using a third-party service.
4.5 Liability​
Yumpie Token has no control over, or liability for, the delivery, quality, safety and legality or any other aspect of any goods or services received or purchased from Coinbase or Metamask.
5. Risk assessment​
Yumpie Token, in accordance with international requirements takes a risk-based approach to combating money laundering and the financing of the terrorism. By applying a risk-based approach, Yumpie Token can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate with the identified risks. This makes it possible for resources to be allocated in the most efficient way. The principle is to allocate resources corresponding to priorities so that the highest risks are given the closest attention.
6. AML and KYC Policy​
6.1 Acceptance​
By participating in the Yumpie Token Initial Coin Offering (ICO), defined as making a Yumpie Token token purchase through the specific method stated in clause 4 of this AML and KYC Policy, the User explicitly agrees to comply with the following terms. Prior to participating in the ICO, the User is required to carefully read, understand, and accept the Terms of Use and Data Protection Policy available at https://yumpie.app and https://yumpie.live/.
In addition to the aforementioned policies, certain services provided on our platform may be subject to additional agreements, which will be applicable to the User when using those specific services. It is essential for the User to review and abide by any such additional agreements related to the provided services.
It is crucial to note that by joining the Yumpie Token ICO, the User acknowledges the significance of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. The User agrees to cooperate fully with Yumpie in adhering to the applicable AML and KYC regulations and providing any required information and documentation promptly.
Failure to comply with this AML and KYC Policy and/or any other related terms and policies may result in restrictions on accessing our services, and in extreme cases, may lead to the termination of the User's account or participation in the ICO.
The User's commitment to adhering to this AML and KYC Policy is of utmost importance to ensure the integrity and legality of our platform. By participating in the Yumpie Token ICO, the User demonstrates their understanding of the significance of AML and KYC procedures and their willingness to be a responsible and compliant participant.
Should the User disagree with any part of this AML and KYC Policy, the Terms of Use, or the Data Protection Policy, they must refrain from using our services and accessing the website.
Yumpie is committed to maintaining a secure and compliant environment for all its users and appreciates the User's cooperation in achieving this objective. Together, we can foster a trustworthy and safe ecosystem for everyone involved.
This AML and KYC Policy is subject to change without prior notice. Users will be notified of any modifications, and it is their responsibility to remain informed about the latest policies.
6.2 Privacy policy​
User’s identification information will be collected, stored, shared and protected strictly in accordance with the Yumpie Token’s Privacy Policy and related regulations.
7 Restrictions​
Users to whom U.S American or Canadian tax law applies must not participate in the Yumpie Token Launchpad ICO.