SYNCFAB Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC
Policy”) is designated to prevent and mitigate possible risks of SYNCFAB being involved in any kind
of illegal activity.
AML/KYC Policy covers the following matters:
1. Verification procedures.
2. Compliance Officer.
3. Monitoring Transactions.
4. Risk Assessment.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”).
According to CDD, SYNCFAB establishes its own verification procedures within the standards of
anti-money laundering and “Know Your Customer” frameworks. SYNCFAB uses Identity Mind Global as their verification service provider. Their AML/KYC Policy is HERE.
1.1. Identity verification
SYNCFAB’s identity verification procedure requires the User to provide SYNCFAB with reliable,
independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes SYNCFAB reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
SYNCFAB will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and SYNCFAB reserves the right to investigate certain Users who have been determined to be risky or suspicious.
SYNCFAB reserves the right to verify User’s identity in an on-going basis, especially when their
identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, SYNCFAB reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
Once the User’s identity has been verified, SYNCFAB is able to remove itself from potential legal
liability in a situation where its Services are used to conduct illegal activity.
The Compliance Officer is the person, duly authorized by SYNCFAB, whose duty is to ensure the
effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s
responsibility to supervise all aspects of SYNCFAB’s anti-money laundering and counter-terrorist
financing, including but not limited to:
a. Collecting Users’ identification information. 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 records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
The Users are known not only by verifying their identity (who they are) but, more importantly, by
analyzing their transactional patterns (what they do). Therefore, SYNCFAB relies on data analysis
as a risk-assessment and suspicion detection tool. SYNCFAB performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
1) Check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple
data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
2) Case and document management.
With regard to the AML/KYC Policy, SYNCFAB will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor Users’ 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.