This Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy”) of UAB KUNA Pro (hereinafter "KUNA Pay", "We" or "Us") was prepared in accordance with the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, Proceeds of Crime.
Money laundering and terrorist financing pose significant risks to the integrity and stability of the global financial system, and as a responsible member of the international community, We recognize the importance of combatting these threats. As a result, We are committed to implementing a comprehensive of Anti-Money Laundering (“AML”) and Combating Terrorism Financing (“CTF”) program that adheres to the highest standards of legal and regulatory compliance.
The Policy is designed to represent the basic standards of AML and CTF procedures, which will be strictly complied with by Us.
All definitions in this Policy are used within the meaning of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing and Proceeds of Crime.
The purpose of this Policy is to ensure that We comply with the rules and regulations set out in the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing.
Money laundering is the process of hiding the true origin of money obtained through illegal activities. This process involves disguising the proceeds of criminal activity as legitimate funds.
Money laundering plays a fundamental role in facilitating the ambitions of the drug trafficker, the terrorist, the organized criminal, the insider dealer, and the tax evader, as well as the many others who need to avoid the scrutiny from the authorities that sudden wealth brings from illegal activities.
Terrorist financing is the process of providing funds to individuals or groups to carry out acts of terrorism. Terrorists may move or transfer funds and assets through various methods, including:
The operators of the Kuna Pay platform are:
We are obliged to verify your data as it is required by:
Kuna Pay is accountable to the:
You cannot use KUNA Pay's services without passing the KYC procedure. We are committed to comply with all relevant legal requirements in the field of AML/CTF.
Failure to submit the required information and documents or provision of incorrect or incomplete information and documents, or failure to comply with our other requests will result in our services being unavailable to you.
Customer Due Diligence (“CDD”) is a process used by Us to identify and verify your identity and assess the risks associated with doing business with you.
The CDD process helps Us to understand who you are, what business you have, and what risks you may pose and enables Us to implement appropriate measures to mitigate those risks. It is a key component of AML and CFT compliance programs.
Customer Due Diligence Measures include:
We also reserve the right to determine the origin of your assets, to establish your proof of address, and collect other relevant information to evaluate the risk of Money Laundering, Terrorist Financing, and other illicit activities.
When applying CDD measures We are obliged to identify both the Merchant and the Merchant Authorized Representative.
The following persons may act as Merchant Authorized Representative(s):
In order to identify and verify Merchant Authorized Representative(s), We shall obtain the following data:
The Merchant Authorized Representative(s) must fill out our Questionnaire, providing us with the following data:
Please note that we reserve the right to ask you for information regarding your customers (for example, KYC data - passport, address, source of funds, etc.). We only need this data if we have reasonable doubts about the legitimacy of the funds received from the Merchant's customers to their KUNA Pay account. We strongly encourage Merchants to conduct KYC on their customers where applicable.
For client identification purposes, We use the services of our trusted partner Sum and Substance Ltd (“SumSub”). SumSub collects and stores your data on our behalf.
Sum and Substance Ltd. was incorporated and registered in England with company number 09688671. Sumsub being a software-as-a-service business, takes its responsibilities with regard to the requirements of the EU GDPR and UK GDPR very seriously.
Besides SumSub We can use publicly available databases, different search engines, and other possible legal methods of data verification.
We do not serve the following customers:
We will not accept as Сustomers, persons or entitled from the following countries: Afghanistan, Algeria, Belarus, Benin, Burkina Faso, Burma, (Myanmar), Cabo Verde, Cambodia, Central African Republic, China, Cuba, Crimea (region of Ukraine), Côte d'Ivoire, Congo, Democratic People's Republic of Korea, Dem. Rep. of Ethiopia, Dominican Republic, Donetsk (region of Ukraine), Eritrea, Federal Republic of Ambazonia, Ghana, Guatemala, Guyana, Guinea, Guinea-Bissau, Haití, Honduras, Iran, Iraq, Jamaica, Japan, Jordan, Kenya, Kosovo, Laos, Liberia, Lebanon, Libya, Luhansk (region of Ukraine), Mali, Morocco, Mozambique, Myanmar, Nagorno-Karabakh (temporarily occupied by Russia), Nicaragua, Nigeria, Northern Cyprus, Pakistan, Philippines, People's Republic of China, Russia, Senegal, South Sudan, Syria, Somalia, Sri Lanka, Trinidad and Tobago, Transnistria (temporarily occupied by Russia), territories of Georgia temporarily occupied by Russia (Abkhazia and South Ossetia), Uganda, USA, Vanuatu, Venezuela, Yemen, Zimbabwe.
Persons or entities from jurisdictions where a particular license or permit is required will not be served if we have not received such a permit or license.
Your data will be retained within the provision of our services to you and 5 years after our Business Relationship with you is over.
In some cases, We will keep the data longer if We are required to do so by law or other legal requirements.
We cooperate with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to us and replying to queries within a reasonable time, following the duties, obligations, and restrictions arising from legislation.
We take our AML obligations seriously and are committed to preventing and detecting money laundering and terrorist financing. We will continue to monitor and update our policies and procedures to ensure that We remain in compliance with all applicable AML regulations.
We reserve the right to modify or update this AML Policy at any time and for any reason, with or without notice. It is your responsibility to review this AML Policy periodically for any changes, so we urge you to make a copy of the text of this AML Policy for future reference. Your continued use of the services following the posting of any changes to this AML Policy will signify your acceptance of those changes.
You can find the current version of the Policy at the top right of this page.
If you have any comments or questions with respect to this Policy please feel free to contact us via email: email@example.com
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