Last Updated: 20 February 2025

It is important to carefully review NEIVE's Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policies, as they outline critical compliance obligations and responsibilities.

NEIVE's AML/CFT Policies and Procedures

This document provides a comprehensive overview of NEIVE's Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) policies and procedures. It serves as a general informational guide and does not constitute a legally binding agreement for NEIVE or any other entity or individual.

A. Principles and Methods of NEIVE AML/CFT Measures

NEIVE is committed to robust AML/CFT measures in accordance with regulatory requirements in the European Union, particularly under the Markets in Crypto-Assets (MiCA) regulation. As part of our commitment, we will:

•   Conduct thorough due diligence when engaging with our clients and their authorized representatives.

•   Operate under strict ethical and compliance standards to prevent the initiation or continuation of any business relationship that may contribute to money laundering or terrorism financing.

•   Cooperate fully with relevant regulatory and law enforcement authorities to mitigate the risks associated with financial crimes.

B. NEIVE's Risk Assessment and Risk Mitigation Methodology

Risk Assessment

Given NEIVE’s presence within the European Union and compliance with MiCA regulations, we primarily serve retail and institutional clients. To ensure effective risk assessment, we will:

• Maintain detailed records and documentation on client identities and geographical locations within the European Union and beyond.

• Conduct ongoing screening of clients, their associates, and authorized representatives against lists of designated individuals and entities, including those under international sanctions regimes such as, but not limited:

      o Democratic People's Republic of Korea

      o Democratic Republic of the Congo

      o Iran

      o Libya

      o Somalia

      o South Sudan

      o Sudan

      o Yemen

      o UN, OFAC and EU sanctions lists.

Risk Mitigation

In the event that an individual or entity appears on a designated sanctions list, NEIVE will not engage in any business relationship with them. We will also enhance monitoring and reporting procedures to ensure strict compliance with MiCA and other relevant regulatory frameworks.

C. New Products, Practices, and Technological Innovations

NEIVE will proactively assess and mitigate potential money laundering and terrorist financing risks arising from:

•   The development of innovative financial products and business models, including alternative delivery mechanisms.

•   The adoption of emerging financial technologies, particularly those that facilitate anonymity, such as digital tokens and blockchain-based transactions.

Additionally, NEIVE will ensure that all new financial instruments and technologies align with MiCA regulations, implementing safeguards to enhance transparency and mitigate risks associated with illicit financial activities.

D. Approach to Client Due Diligence (CDD)

NEIVE does not open, maintain, or accept anonymous or pseudonymous accounts under any circumstances.

We shall not engage in business relationships or execute trades for clients when there are reasonable grounds to suspect that their assets or funds originate from drug trafficking or other illicit activities. In such cases, a Suspicious Transaction Report (STR) will be filed with the relevant Financial Intelligence Unit (FIU).

NEIVE will conduct Client Due Diligence (CDD) under the following conditions:

•   When establishing a business relationship with any client.

•   When executing transactions for clients with whom we do not have an established business relationship.

•   When receiving cryptocurrency transfers on behalf of clients who do not have an established business relationship with us.

•   When there are suspicions of money laundering or terrorist financing.

•   When there are doubts about the accuracy or sufficiency of client-provided information.

If we suspect that multiple transactions are linked or that an individual transaction has been intentionally broken down into smaller amounts to evade AML/CFT regulations, we will consider them as a single transaction and apply AML/CFT principles accordingly.

Client Verification

To verify the identity of our clients, we require the following information:

•   Full name, including any aliases.

•   A unique identification number (e.g., identity card number, birth certificate number, or passport number). For non-natural persons, the business registration number.

•   Registered address or business address, and the principal place of business if different.

•   Date of birth, establishment, or registration.

•   Nationality or place of registration.

For legal entities, in addition to the above, we will verify the legal structure, governing statutes, and persons in positions of authority, such as directors and/or executive officers. This includes obtaining their full names, aliases (if any), and identification details.

Identity Verification

NEIVE will use independent, reliable sources of data, documents, or information to verify the identity of all clients. For legal entities, we will further verify their proof of existence, statutes, and governing regulations.

Verification of Client Representatives

If a client appoints representatives to act on their behalf, NEIVE will:

•   Identify each representative by collecting their full name, identification number, residential address, date of birth, and nationality.

•   Verify the authenticity of their authorization through formal documentation.

•   Obtain and record a specimen signature for verification purposes.

If the client is a government entity, we will gather only the information necessary to confirm their claimed identity.

Identification and Verification of Beneficial Owners

We will determine if clients have beneficial owners and take reasonable steps to verify their identities through independent and reliable sources.

For legal persons, we will:

•   Identify individuals who hold ultimate ownership or control over the entity.

•   In cases where ownership is unclear, establish the individual(s) who have the highest level of control.

•   If no such person is identified, we will identify a natural person with enforcement authority over the legal person.

For legal arrangements such as trusts, we will:

•   Identify the settlor, trustee, protector (if applicable), and beneficiaries.

•   Establish individuals with ultimate ownership or control.

NEIVE is required to verify the beneficial owners of the following clients:

•   Publicly listed companies subject to full disclosure requirements.

•   Financial institutions and entities supervised for AML/CFT compliance in accordance with the Financial Action Task Force (FATF) guidelines.

•   Investment vehicles managed by financial institutions or entities subject to FATF standards.

This verification process applies unless there is reasonable suspicion regarding the accuracy of client information or concerns related to money laundering or terrorist financing.

Purpose and Nature of Business Relations and Transactions

When establishing a business relationship or processing a transaction, NEIVE will assess the purpose and intended nature of the client's activities. If required, we will request additional details regarding the origin of funds and the rationale behind the transaction.

Review of Transactions Without an Open Account

If a transaction is executed without an account being opened, NEIVE will review past transactions of the client to confirm consistency with their profile and declared financial activity. This review ensures that the transaction aligns with the client's risk assessment and source of funds.

Particular attention will be given to transactions that are:

•   Complex, unusually large, or structured to avoid detection.

•   Conducted without an apparent economic purpose.

Any suspicious findings will be recorded and reported to the relevant authorities.

Continuous Monitoring

NEIVE will maintain continuous monitoring of client relationships, scrutinizing account activities and transactions to ensure compliance with AML/CFT regulations. Specific measures will be taken for:

•   Transactions involving cryptocurrency transfers to or from financial institutions.

•   Financial institutions supervised for compliance with FATF AML/CFT standards.

All high-risk transactions will undergo enhanced monitoring and investigation, with findings documented and made available to regulatory authorities upon request.

If there are reasonable grounds to suspect that an existing client relationship is linked to money laundering or terrorism financing, NEIVE will:

•   Justify and document the rationale for maintaining the relationship.

•   Apply enhanced due diligence and ongoing monitoring procedures.

•   Obtain senior management approval before continuing business with the client.

CDD for Non-Face-to-Face Business Relationships

NEIVE will implement specific policies to address risks associated with non-face-to-face transactions and relationships, including:

•   Additional verification measures for digital-only interactions.

•   Engaging third-party auditors or independent consultants to evaluate security and impersonation risks.

Reliance on Third-Party Due Diligence

If NEIVE acquires another payment service provider, we will reassess the acquired clients unless:

•   Complete client records, including CDD data, are obtained.

•   The acquiring entity has conducted proper due diligence on the AML/CFT controls of the acquired business.

Verification Timing and Transaction Screening

Client identity verification must be completed before:

•   Establishing a business relationship.

•   Executing a transaction where no prior relationship exists.

•   Facilitating cryptocurrency transactions.

Under exceptional circumstances, verification may be deferred, provided that risks are effectively managed and verification is completed as soon as possible.

Handling Incomplete Due Diligence

If we are unable to complete CDD procedures, NEIVE will not proceed with the transaction or business relationship. Additionally, we will assess whether the situation warrants an STR filing.

Joint Accounts

For joint accounts, each account holder must undergo full CDD procedures as if they were individual clients.

Screening and Compliance Reporting

All clients, representatives, and beneficial owners will be screened against regulatory sanctions lists and risk databases. NEIVE will:

•   Screen clients before establishing a business relationship or executing a transaction.

•   Regularly update client screenings based on new regulatory lists.

•   Maintain records of all screenings and findings for compliance and reporting purposes.

NEIVE remains committed to upholding the highest AML/CFT compliance standards in alignment with the MiCA regulatory framework and international best practices.

E. Our Approach to Enhanced Client Due Diligence

Politically Exposed Persons (PEPs)

We shall employ all reasonable measures to determine whether a client, a natural person acting on behalf of a client, a related party of a client, or a beneficial owner of a client is a Politically Exposed Person (PEP) or an individual closely associated with a PEP.

If a client or any of their beneficial owners is identified as a PEP, a family member, or a close associate of a PEP, we shall implement the following enhanced due diligence measures in addition to our standard CDD procedures:

•   Obtain approval from senior management before establishing or continuing a business relationship with the client.

•   Take reasonable steps to ascertain the source of the client’s wealth and funds, including those of any beneficial owners.

•   Conduct enhanced monitoring of business relations with the client, increasing the level and nature of oversight for any unusual transactions.

High-Risk Categories

We recognize that certain circumstances may indicate a heightened risk of money laundering or terrorist financing, including but not limited to:

•   Clients or beneficial owners from countries or jurisdictions subject to Financial Action Task Force (FATF) countermeasures.

•   Clients or beneficial owners from jurisdictions with inadequate AML/CFT frameworks, as determined by NEIVE, regulatory authorities, or other foreign oversight bodies.

For clients identified as higher risk, NEIVE shall implement enhanced due diligence measures and comply with any directives issued by relevant authorities regarding heightened AML/CFT risks.

F. Approach to Bearer Negotiable Instruments and Cash Payout Restrictions

NEIVE strictly prohibits the use of bearer negotiable instruments for any payment transactions. Additionally, we shall not issue or facilitate any cash payments as part of our business operations.

G. Approach to Value Transfers (Implementation as Required)

Ordering Institution Responsibilities

Before executing a value transfer, NEIVE shall:

•   Identify the originator and take reasonable measures to verify their identity if not previously completed.

•   Maintain detailed records of the value transfer, including:

         o The transaction date.

         o The type and amount of digital assets transferred.

         o The value date.

In value transfer memos or payment instructions, NEIVE shall include:

•   The originator’s name.

•   The originator’s account number (or unique transaction reference number, where applicable).

•   The beneficiary’s name.

•   The beneficiary’s account number (or unique transaction reference number, where applicable).

Value Transfers Above a Specified Threshold

For value transfers exceeding a defined threshold, NEIVE shall:

•   Identify and verify the originator.

•   Include additional details in the payment instructions, such as:

o          o The originator’s residential or registered business address.

o          o The originator’s unique identification number.

o          o The originator’s date and place of birth (or incorporation/registration for legal entities).

NEIVE shall ensure that all required originator and beneficiary details are securely submitted to the beneficiary institution and that comprehensive transaction records are maintained. If compliance with these requirements is not possible, NEIVE shall refrain from executing the value transfer.

Beneficiary Institution Responsibilities

If acting as a beneficiary institution, NEIVE shall take reasonable steps to identify value transfers that lack the necessary originator or beneficiary details. For digital asset transactions paid out in cash or cash equivalents, we shall verify the identity of the recipient before processing the transfer.

Before executing a value transfer with incomplete originator or beneficiary details, NEIVE shall review the transaction and document any follow-up measures taken.

Intermediary Institution Responsibilities

If NEIVE functions as an intermediary in a value transfer, we shall:

•   Retain all transaction-related data.

•   Promptly and securely transmit all required information to the next intermediary or beneficiary institution.

•   Maintain records of received value transfer information for a minimum of five years.

•   Implement reasonable measures to detect and flag value transfers lacking necessary originator or beneficiary details during automated processing.

H. Record Keeping

NEIVE shall retain all necessary records and documentation for a minimum period of five years, in compliance with applicable legal and regulatory requirements. These records include client identification data, transaction details, and any related correspondence, ensuring they are readily available for audit or regulatory review.

I. Personal Data Protection

We are committed to safeguarding the personal data of our clients in accordance with applicable data protection laws and regulatory requirements. We shall implement appropriate security measures to ensure that client data remains confidential and protected against unauthorized access, use, or disclosure.

J. Suspicious Transaction Reports (STRs)

NEIVE shall promptly notify the relevant authorities and file Suspicious Transaction Reports (STRs) in accordance with legal obligations. Additionally, we will maintain comprehensive records of all transactions associated with STR filings to ensure regulatory compliance and facilitate audits.

K. Compliance, Audit, and Employee Training Policies

To reinforce our commitment to Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), NEIVE will:

•   Appoint an AML/CFT compliance officer at the management level to oversee compliance programs.

•   Maintain independent audit capabilities to regularly review and assess AML/CFT processes.

•   Implement proactive training programs to educate employees on AML/CFT risks, regulatory obligations, and best practices.

Enterprise-Wide Money Laundering/Terrorism Financing Risk Assessment

NEIVE shall conduct a structured enterprise-wide risk assessment of money laundering and terrorism financing threats in three key phases:

Phase 1: Assessment of Inherent Risk

We shall evaluate the level of inherent risk by analyzing:

•   Client and entity profiles: Assessing the risk levels associated with clients and business entities we engage with.

•   Products and services: Identifying AML/CFT vulnerabilities associated with our cryptocurrency OTC services and other financial offerings.

•   Geographical risk exposure: Ensuring we do not engage with clients or entities included in lists of designated individuals and entities under international sanctions or regulatory restrictions.

Phase 2: Assessment of Mitigating Controls

We shall assess and enhance the effectiveness of our internal controls and monitoring systems to mitigate identified risks. Clients deemed to be high-risk will be subject to enhanced due diligence procedures and continuous monitoring.

Phase 3: Assessment of Residual Risk

Following the implementation of mitigating controls, NEIVE shall evaluate any remaining exposure to money laundering and terrorism financing risks. This phase ensures that our risk management strategies effectively minimize vulnerabilities while maintaining compliance with regulatory frameworks.

NEIVE team