Anti-Money Laundering Policy
AML(anti-money laundering policy)
Effective date: 01.03.2022.
Updated on 05/27/2022.
This AML Policy (hereinafter referred to as the Policy) regulates the activities of Barry24.com , regarding the fight against money laundering and its involvement in the fight against money laundering and the financing of terrorist activities.
Terms and definitions
Barry24.com – this is a trademark of the systеm that provides Users with the opportunity to exchange digital and electronic currency.
Service is a systеm for providing Internet services for the exchange, sale and purchase of digital and/or electronic currencies.
A user is any individual who uses the services of the service barry24.com .
Digital currency – Bitcoin, Litecoin, Ethereum and any other currencies based on blockchain.
Electronic currency – funds held in the accounts of users of electronic payment systems (Qiwi, Yandex Money, etc.).
Service services – assistance in conducting P2P transactions between individuals for the purchase and sale and exchange of digital currencies, as well as other services, information about which is posted on the Service showcase.
Card verification is the verification of the ownership of the card (or account) to its owner. The conditions for checking the affiliation are set by the Service, made at a time for each new account (card) The user.
Money laundering – giving a lawful form to the possession, use or disposal of funds or other property obtained as a result of the commission of a crime. Barry24.com strictly follows the laws prohibiting us or any of our employees from knowingly engaging in or attempting to engage in any kind of activities related to money laundering in one way or another. Our anti-money laundering policy is aimed at improving the security of customers and the services provided by the Service.
Financing of terrorism is the deliberate provision or collection by any means, directly or indirectly, of funds with the intention of using these funds or on condition that they will be used to commit terrorist acts.
2. Activities undertaken within the framework of compliance with the AML Policy
Service Administration Barry24.com Realizing the public danger of crimes related to money laundering and the financing of terrorist activities, has developed a set of organizational and legal measures to comply with the provisions of national legislation, as well as the requirements of the intergovernmental organization FATF.
The European regulation of AML is based on a number of legislative directives. Namely, the EU issued the Sixth Anti-Money Laundering Directive (6AMLD), which entered into force on December 02, 2018.
Other legislative acts aimed at combating the legalization of proceeds from crime and the financing of terrorism are the following acts:
- 5th Anti-Money Laundering Directive ((EU) 2018/843);
- Proceeds of Crime Act 2002;
- Terrorism Laws of 2000 and 2001;
- The Anti-Terrorism Act of 2008;
- Treasury Sanctions Notices;
Application of the KYC policy
(know your customer – know your customer).
- Mandatory identification of Users who are allowed to make transactions on our Service. To verify the User, the Administration has the right to request the following data: take a photo (“selfie”) with a citizen’s identity document: a scanned copy of the front and back sides of the official photo ID, that is, a valid passport, driver’s license or other national identity card; to confirm the place of residence: an official document issued within the last 3 months, with a clear indication of the name and address of the client specified during registration on the website Barry24.com . This can be a utility bill (for water, electricity or a landline phone) or a bank statement. The copy must inсlude: full name, full address of residence, date of issue (within the last 3 months), the name of the issuing authority, with an official logo or seal; provide a copy of the front and back sides of the bank card and/or a photo of your bank card taken against the background of the main page of the Service (showcase with services). For privacy and security, only the last 4 digits of your credit card should be visible. It is allowed to hide 3 digits on the back of the card (CVV code).
- Service Administration Barry24.com will take steps to confirm the authenticity of documents and information provided by Users. Identification information will also be checked using secondary sources, and the service Administration reserves the right to continue investigating cases in order to obtain full confidence in the authenticity of the documentation provided.
- Service Administration Barry24.com reserves the right to monitor the User’s data on an ongoing basis, especially in cases where his identification information has been changed or his activity has seemed suspicious (unusual for a particular User). In addition, the Administration reserves the right to request current documents from Users, even if they have been authenticated in the past.
- Implementation of continuous monitoring of operations passing through the Service. We constantly monitor all applications created on the site Barry24.com . The administration of the service notifies Users about the ban on carrying out exchange operations from third parties using their account.
- Appointment of a responsible person (MLRO — Money Laundering Reporting Officer) exercising control and supervisory powers to implement the provisions of this Policy.
- Application of a risk-based approach (RBA — Risk-Based Approach). We implement different levels of verification, depending on the volume and number of operations performed by the User.
- Improving the professional skills and knowledge of the team’s employees Barry24.com in terms of compliance with the requirements of the Policy.
- Interaction with state bodies in cases established by law. If we receive an official request from law enforcement or judicial authorities, we will be obliged to provide them with the requested information. Also, the service Administration has the right to provide the data requested by the official representatives of payment systems.
- Improving the security of the service software Barry24.com . We care about the reliability and security of your transactions. In this regard, we are constantly improving our IT department, whose main task is to protect the site from unauthorized access by intruders.
- Service Administration Barry24.com , in cases prescribed by law, a regulatory requirement may be required to verify the source of fiat money and/or cryptocurrencies to ensure that the sources of funds that the Client uses for exchange are legitimate. As a document confirming the source of origin of Funds, there may be a bank statement for fiat money or a video showing the details of a cryptocurrency wallet transaction.
- In accordance with this Policy, the Administration of the service will:
- — monitor all transactions. The Administration reserves the right to ensure the transmission of messages about the suspicious nature of transactions to the appropriate law enforcement agencies through a Responsible Official;
- — request any additional information and documents from the User in case of suspicious transactions, as well as at the request of the regulator (An exchange, a government agecy or other organization with appropriate legal grounds can act as a regulator.);
- — suspend or terminate the User’s account if there is a reasonable suspicion that such a User is involved in illegal activities.
- However, the above list is not exhaustive, and the Responsible Official will monitor User transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or which should be treated as bona fide.
- Country Of Residence. This Policy defines our risk criteria for AML/CTF. To reduce this risk, the service Administration Barry24.com does not accept clients who reside in the following countries with an increased risk criterion:
Sources used for categorization:
- Transparency International;
- Know Your Country;
- List of FATF jurisdictions with a high level of risk;
- List of high-risk EU jurisdictions;
- Countries where digital assets are banned or there are restrictions on trade;
- Countries where digital assets are not banned;
- Countries subject to the UN Security Council sanctions regime.
- All customers residing in the countries listed below are prohibited from using the service Barry24.com and cannot be accepted as Users.
- Any customers from these countries will be denied service, and any funds will be returned to the source.
Full list of prohibited jurisdictions:
USA
Afghanistan
Albania
Angola
Algeria
Bangladesh
Barbados
Bolivia
Botswana
Burma (Myanmar)
Burundi
Cambodia
Central African Republic
Chad
Congo
Conakry
Ivory Coast
Crimea (Ukraine)
Cuba
Democratic People’s Republic of Korea (DPRK)
Ecuador
Egypt
Equatorial Guinea
Eritrea
Ghana
Guinea-Bissau
Haiti
Guyana
Iran
Iraq
Lao People’s Democratic Republic
Lebanon
Libya
Mali
Morocco
Myanmar
Nepal
Nicaragua
Northern Macedonia
Pakistan
Panama hat
Qatar
Saudi Arabia
Somalia
South Sudan
Sudan
Syria
Tunisia
Uganda
Vanuatu
Venezuela
Yemen
Zimbabwe
Jamaica
Service Administration Barry24.com it also does not accept clients from disputed territories, as they do not provide generally recognized official documents, including:
Donetsk People’s Republic (DPR) / Luhansk People’s Republic (LPR)
Pridnestrovian Moldavian Republic
The Nagorno-Karabakh Republic
Republic of Abkhazia
Republic of Somaliland
Republic of South Ossetia
Turkish Republic of Northern Cyprus
Republic of China (Taiwan)
Passports issued by the Russian Federation in Crimea and passports issued to residents of Donetsk and Luhansk regions of Ukraine are not subject to verification
Republic of Kosovo
Sahrawi Arab Democratic Republic
Republic of Artsakh
KYT Policy
(Know Your Transaction)
Effective date: 01.11.2021.
Updated on 05/27/2022.
The KYT (Know Your Transaction) policy is aimed at identifying the transaction client in case of a precedent when the Service has reasonable suspicions that the Client is using Barry24.com not for its intended purpose.
Such a precedent may arise if the Service suspects the Client of illegal actions that can be qualified as laundering or an attempt to launder digital assets obtained illegally or the funds have a frankly criminal origin. For these purposes, the Service has the right to use any legitimate information, third-party means of analyzing the origin of digital assets, as well as its own screening systеm developments.
In this case, the Service Barry24.com reserves the full right to:
- Require the Client to provide additional information revealing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
- Block the account and any transactions related to the Client, transfer to the financial activity control and/or law enforcement agencies at the place of registration of the Service and, if necessary, at the Client’s registration address all the information and documents available on the incident;
- To demand from the Client documents confirming the identity, physical existence, registration address, solvency;
- To return digital assets only to the details from which the transfer was made or to switch to other details, after a full check by the security service of the Service, if it was possible to verify the legal origin of the Client’s funds;
- To refuse the Client to withdraw funds to the account of third parties without explanation;
- Withhold the Client’s funds until the incident is fully investigated;
- The Service reserves the right to monitor the entire chain of transactions in order to identify suspicious transactions;
- The Service reserves the right to refuse to provide the service to the Client if the Service has reasonable suspicions about the legality of the origin of digital assets and to withhold funds on special accounts of the Service;
- The Service reserves the right to refuse to provide the service to the Client if the Service has reasonable suspicions about the legality of the origin of digital assets and to withhold funds in special accounts of the Service if it is impossible to track the entire chain of movement of digital assets from the moment of their appearance.
- Conditions for making a refund of funds stopped for verification based on the results of the AML analysis of the transaction:
- The refund is carried out after a full check by the security service of the Service, which may inсlude detailed verification of the sender. The refund is carried out minus a commission of up to 5% of the transaction amount to cover the labor costs of processing the application and organizing a refund.
- The refund, subject to the approval of the Service, will be processed by the Service within 7 (seven) calendar days, starting from the date when the User was notified with the decision of the Service regarding his request for a refund.
- When making a refund, after passing the verification (verification), the user is obliged to confirm the details for receiving a refund.
