MUSIC ALLIGATOR LTD
AML/KYC Policy
Original Credit Transaction (OCT) allows our Company to optimise direct payouts to artists. While payouts can be facilitated through OCT, they must meet tax legislations of the United Kingdom. This way direct payments can be made to artists payment cards significantly simplifying the process and reducing costs.
AML & KYC POLICY
Having regard for the safety of the users and due to the legal requirements, The European Union, The United Kingdom and other countries, MUSIC ALLIGATOR LTD has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating money-laundering and terrorist financing) as it is required from banks and other financial institutions.
The purpose of those policies is an effective combating of money-laundering and terrorist financing (AML / CTF) on our platform by proper identification of actual users of our accounts and supervision of OCT transactions. We shall identify and cease transactions made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviours.
Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to you some of the general rules and stipulations of our policies which directly concern you and affect the services we render.
USER’S IDENTIFICATION
In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to accept payments from our website. This is the reason why we collect ID scans, which authenticity is verified with our AML officers.
All participants of transactions shall provide AML Officer with the necessary documents, such as proof of identity and proof of address, as well as any other documents if necessary.
Identity Proof (Passport, Driving License)
Address Proof (Passport, Electricity Bill, Bank Account Statement, Gas Bill, Lease agreement along with last 3 months, rent receipt)
We require sending “selfie” or your recording with ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is done manually by our customer support services.
In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arose.
If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are the authentic we won’t be able to let you execute any transactions.
USER’S IDENTIFICATION – COMPANIES
In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company.
Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such users is doing “manually” and is considerably more time-consuming.
POLITICALLY EXPOSED PERSONS (PEPs)
MUSIC ALLIGATOR LTD recognizes the significance of Politically Exposed Persons (PEPs) in the context of anti-money laundering (AML) and counter-terrorist financing (CTF) efforts. PEPs encompass individuals who currently or have previously held prominent public positions or functions. In adherence to regulatory requirements, we have instituted a comprehensive framework for conducting enhanced due diligence (EDD) on PEPs.
MUSIC ALLIGATOR LTD employs a multi-faceted approach to identify and verify Politically Exposed Persons (PEPs). Our process includes:
Screening Databases: We utilize comprehensive global databases that contain PEP and sanctions lists. These databases are regularly updated to ensure accuracy.
User Disclosure: During the registration and onboarding process, users are required to disclose any PEP connections or affiliations. We cross-reference this information with our database checks.
Ongoing Monitoring: Our systems continuously monitor user profiles and transactions for any indications of PEP status. Suspicious patterns or associations trigger further investigation.
Risk Assessment: We categorize users into risk profiles based on their PEP status and transactional behavior. High-risk PEPs undergo more stringent due diligence.
DUE DILIGENCE
We consider due diligence as a multifaceted process, encompassing the collection of comprehensive information on users, the evaluation of their financial activities, and the discernment of transactional nuances. The nature and extent of due diligence may vary based on the perceived risk associated with each user or transaction.
Our due diligence procedures are exhaustive and encompass the following elements:
User Information Collection: We gather comprehensive user information, including legal names, addresses, contact details, and relevant identification documents.
Source of Funds Verification: We scrutinize the source of funds for transactions, ensuring they are legitimate and not derived from illegal or prohibited activities.
Transaction Monitoring: Our advanced software continuously monitors user transactions for unusual or suspicious behavior, such as high-frequency transactions or large transfers. Background Checks: We conduct background checks, including criminal record checks where permitted by law, to ascertain the integrity of users.
ENHANCED DUE DILIGENCE (EDD)
Enhanced Due Diligence (EDD) is initiated when heightened risk factors are identified. EDD procedures may include:
In-Depth Interviews: We conduct interviews with the user to gain a deeper understanding of their financial activities, source of wealth, and any potential high-risk associations.
Third-Party Verification: EDD may involve the verification of information with third parties, such as banks, regulators, or legal authorities.
Adverse Media Screening: We employ advanced tools to screen for adverse media mentions or negative news associated with the user.
Enhanced Transaction Monitoring: Transactions involving users under EDD are subject to continuous and real-time monitoring for unusual patterns or behaviors.
ONLINE VERIFICATION FOR KYC
MUSIC ALLIGATOR LTD has implemented a secure and efficient Online Verification process for Know Your Customer (KYC) purposes:
User Submission: Users provide their personal information and identification documents via our secure online platform.
Document Authentication: Our system utilizes cutting-edge technology to authenticate and verify the authenticity of identification documents. This includes checks for watermarks, holograms, and other security features.
Document Comparison: Our system cross-references the submitted identification documents with user-provided information to ensure consistency and accuracy.
Real-Time Review: The entire verification process is conducted in real-time, with automated checks and manual reviews conducted by our trained verification experts.
Secure Data Handling: We employ robust encryption and security protocols to safeguard user data throughout the verification process.
DOCUMENTATION REQUIREMENTS FOR LEGAL ENTITIES
In the case of legal entities, MUSIC ALLIGATOR LTD imposes stringent documentation requirements to ascertain their identity and assess transactional risk thoroughly. The following is a non-exhaustive list of documents that may be solicited:
Proof of Company Registration and Incorporation: Documentation attesting to the official registration and incorporation of the entity, including relevant registration certificates and articles of incorporation.
Information on Company Ownership: Comprehensive details regarding the beneficial ownership structure of the company, including the identities of ultimate beneficial owners and major shareholders.
Business Licenses and Permits: Copies of relevant business licenses, permits, and authorizations necessary for the lawful operation of the entity.
Financial Statements and Tax Records: Financial statements, tax records, and audited financial reports, where applicable, to gain insights into the financial health and operations of the entity.
Additional Documents: Any other documents or information deemed necessary based on the specific structure, jurisdiction, and regulatory requirements applicable to the entity.
TRANSACTIONS’ MONITORING AND SUPERVISION
Using our proprietary software we also analyse all transactions that take place on our website looking for suspicious and unusual behaviours.
ADDITIONAL VERIFICATION
In some cases, we can require additional documentation proving your real, exact place of residence, education, occupation.
Unfortunately, if our AML specialists decide information received from you don’t clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to relevant authorities.
BASIC AM / CTF RULES
Our operating rules include inter alia as follows:
MUSIC ALLIGATOR LTD does not allow any exceptions in the field of documentation required from users.
MUSIC ALLIGATOR LTD reserves the right to refuse to process the User’s transaction at any time, in case of suspicion of AML / CTF risk.
In accordance with the international law, we are not obliged (or even forbidden) to inform our clients, if we report their behaviours as suspicious to relevant authorities.
SANCTIONED COUNTRIES
In accordance with our policies we do not open accounts and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission) impose high AML / CTF high risk.
Currently, these countries are:
Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russia, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states).
You should remember that this model is a result of the work and experience of our AML team and can be changed as the legal requirements of countries changes as well as a result of gaining new knowledge and experience. In particular transition, limits may change due to periodical audits and verification of efficiency of our procedures. We will keep you updated if any changes would influence your situation.
