NARKASA YAZILIM TİCARET A.Ş.
ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING AND KNOW YOUR CUSTOMER POLICY
Narkasa Yazılım Ticaret Anonim Şirketi (NARKASA) feels obligated to act in accordance with national and international legal regulations regarding anti-money laundering (AML) and counter terrorist financing (CTF).
The “Anti-money Laundering and Counter Terrorist Financing and Know Your Customer (KYC) Policy” (POLICY) is drafted in accordance with international standards and the code on "The Prevention of Laundering of Criminal Proceedings" with no. 5549, the code on "The Prevention of Terrorist Financing" with no. 6415 and regulations and communiqués based on these laws to which NARKASA is subject.
NARKASA has the right to change and update this POLICY at all times in order to comply with international standards, legal regulations, instructions of competent institutions and organizations.
2.1. Fiat money : States the currency which is used for buying products and services and which has been issued and signed by a governmental decision upon the trust that the issued papers cannot be imitated.
2.2. Cryptocurrency : States the digital currency which is encoded through cryptographic methods, whose value is determined in the free market and which has not been issued by a government, central bank, financial institution or e-currency institution, is not centralized, is autonomous and vastly uncontrolled, registered in a global network between individuals (blockchain), can be bought and sold upon anonymous trust, transferred or used for payment or investment goals, is not backed by commodities such as gold or silver and therefore unrequited.
2.3. User: Natural person who opens an account through the NARKASA website or mobile applications in order to make use of the NARKASA services.
2.4. Platform : Websites, mobile applications and API through which buying-selling cryptocurrency, depositing-withdrawing cryptocurrency and fiat money activities are realized.
2.5. Countries at risk : Countries which have insufficient regulations regarding the laundering of criminal proceedings and financing of terrorism, which do not cooperate in combating these crimes or which have been deemed to be at risk by the Republic of Turkey and the competent international organizations (FATF, OECD/IMF etc.).
2.6. Suspicious transaction: If there is any information, suspicion or suspicious activity that the asset subject to the transaction made or attempted to be carried out with or via NARKASA is obtained by illegal means or used for illegal purposes or is used for terrorist activities or terrorist organizations, terrorists or terrorist financiers in this context or is related with or connected thereto.
3.OBLIGATIONS OF NARKASA
3.1. Know Your Customer (KYC) Obligation
In order to comply with the anti-money laundering (AML) and counter terrorist financing (CTF) obligations, the ‘Know Your Customer’ (KYC) procedure has to be carried out.
In this regard, the identity of users will be determined in stages and the identification information will be checked for correctness and actuality where possible.
In this context the following information and other necessary information and documents will be requested;
- Name, surname, e-mail address and country (nationality) information of those who open an account on the NARKASA platform,
- Mobile phone information from the user who wants to make a total transaction of 1 BTC by means of transfer between cryptocurrencies,
- International identity card, driver's license, passport, bank IBAN registered in the name of the user and / or account number, swift, credit card information of the user who wants to make a fiat money transaction with a value of or equivalent to a maximum of 500.000,00 Turkish Liras.
- A photo taken with the internationally valid identity document, driver's license or passport document, the address and a subscription invoice which has been issued within the last 3 months prior to the transaction date in name of the user confirming the address, for the user who wants to make a fiat money transaction with a value of or equivalent to an amount exceeding 500.000,00 Turkish Liras
The information received is processed and protected according to “The Processing and Protection of Personal Data Policy” of NARKASA.
The information received is verified and / or updated during subsequent transactions of the user or when NARKASA deems necessary.
Since each user may only have one account on the NARKASA platform, NARKASA also has the right to request information and documents from the user in order to investigate whether the user is acting in someone else's name and to determine the person in whose name is being acted (real beneficiary).
NARKASA pays special attention to the user's complex and unusually large-scale transactions and transactions that do not have apparent reasonable legal or economic purposes, where possible. NARKASA may request information about the purpose of the transaction in this regard.
The status of the user and the transactions made by the user are continuously monitored to see the compatibility with information regarding the user's profession, business activities, employment history, financial status, risk profile and the information regarding fund resources within the scope of his continuous business relationship. The information, documents and records about the user are updated.
The following persons are considered to be at high-risk:
- Persons who are blacklisted on the lists published by the competent authorities with regard to the Prevention of Laundering of Criminal Proceedings and the Financing of Terrorism (lists that are published by the OFAC, OECD, FATF, INTERPOL, EU, UN and the competent authorities of the Republic of Turkey).
- Persons who want to open an account anonymously or with a nickname.
- Persons who refrain from providing the requested information and documents.
- Persons who do not comply with the request for identification and confirmation in case of doubt about the adequacy and accuracy of identification information provided earlier.
- Persons whose account has been canceled, suspended by NARKASA or who are banned from opening an account.
- Persons in countries at risk.
- Persons with political influence or have connections with those with political influence.
NARKASA can take the following additional precautions regarding the persons it regards as being at high risk:
- Additional information about the person himself may be requested.
- It may be requested that the identification information is updated more frequently.
- Additional information about the nature of his business relationship may be requested.
- As much detailed information as possible about the source of the traded assets and user funds may be requested.
- Information about the purpose of the transaction may be requested.
- The entry into a business relationship, the maintenance of the current business relationship, or the execution of the transaction may be deemed dependent upon the approval of the senior official.
- The business relationship may be kept under strict supervision by increasing the number and frequency of the checks applied and by determining the types of transactions that require additional checks.
- In the establishment of a permanent business relationship, it may be required that the first financial transaction is made from another financial institution where the principles regarding the recognition of the person are applied.
NARKASA can reject the requests to open an account of high-risk people in any case, prevent them from using the NARKASA platform and end their relationship.
In addition, NARKASA will not execute the transaction requested by users whose identity cannot be determined or in case sufficient information about the purpose of the user's transaction could not be obtained or when deemed necessary. In case there are doubts about the adequacy and accuracy of the identification information previously obtained and/or this information cannot be updated, the relationship with the user will be terminated.
NARKASA always has the right to change and / or update its Know your Customer (KYC) procedures in accordance with the legislative changes and / or in accordance with the instructions of the competent public institutions and organizations.
3.2. Notification of Suspicious Transactions, Obligation to Provide Information and Documents
Suspicious transactions are reported to the competent institutions and organizations by the legal representatives of NARKASA along with as much information and documents as possible. No financial limit is taken into account in the notification of suspicious transactions. No one, including parties to the transactions, is informed beforehand about notifications made or to be made.
NARKASA may suspend the transaction for which the suspicious transaction notification is made without sharing any grounds, refrain from executing the transaction or take the necessary measures to be requested by the competent institutions or organizations.
NARKASA will provide all types of information and documents to be requested immediately upon the request of the competent institutions and organizations
3.3. Obligation to Maintain and Present
NARKASA will maintain documents related to its obligations and transactions in any environment for a period of 10 years from the date of issuance, its books and records from the last registration date and documents and records related to identification from their last transaction date and present them to the authorities upon request. Necessary measures are taken and applied diligently within the framework of the relevant legislation on the confidentiality of information, documents and records regarding users and user transactions.