Metavest Limited

AML & KYC Policy

Introduction

Metavest is a platform that seamlessly merges digital banking with crypto. It lets the community operate their money efficiently, with components that allow deposit money into a high-yield account, trading in the most appropriate exchanges, and earning interest through DeFi protocols.

Throughout the offering of Metavest services, Metavest could be subject to anti-money laundering regulations. By no means of deviation from or non-compliance with the applicable regulations on this end, Metavest additionally commits to adopt and apply this Anti-Money Laundering and Know Your Customer Policy (“AML&KYC Policy”) irrespective being subject to subject to relevant regulations, in order to identify, prevent and eliminate money laundering, terrorism financing and fraud cases through Metavest.

In addition, Metavest pledges to maintain this AML & KYC Policy to be aligned with anti-money laundering financing regulations applying to itself. Metavest must comply with such regulations and is aware that failure to comply with the relevant regulations exposes Metavest to potentially severe civil and/or criminal penalties.

                           

Compliance Organization & Responsibilities

Metavest management board shall be responsible for the effective execution of this AML & KYC Policy. 

                        
Nevertheless, the Management Board shall appoint a Compliance Officer for the day-to-day implementation of this policy.

The Compliance Officer shall be responsible for ensuring compliance with this Policy, other internal policies and procedures, as well as applicable laws. Duties of Compliance Officers are as follows;
 

• To ensure compliance of this AML & KYC Policy, and thereby Metavest, with the obligations regarding the prevention of money laundering and financing of terrorism and to ensure the necessary communication and coordination with competent authorities or other relevant public or private institutions and organizations;

• To create, maintain and monitor potential amendment necessities of this AML & KYC Policy and submitting it for the approval of the management board;

• To carry out and report activities related to monitoring and internal control regarding the implementation of this AML & KYC Policy;

• To submit training program for the prevention of money laundering and financing of terrorism to the approval of the management board and to ensure the effective implementation of the approved training program
                               

The Compliance Officer shall render all kind of decisions with an independent will. He/she has the authority to request all kinds of information and documents related to the field of duty from all units within Metavest and access them in a timely manner. In this context, his authority is as follows but not limited to;                        

• To access to related information, logs and systems of Metavest,

• To be able to give binding instructions to managers and employees within the scope of preventing money laundering, financing of terrorism or any violation of this Policy,

• To call the management board to a meeting in urgent cases,

• Making decisions to terminate or not to onboard users who are considered as risky under this Policy.                    

1. Know-Your-Customer 

Metavest uses state-of-the-art and risk-based checks throughout its user onboarding processes. Below are the phases of checks applied by Metavest to onboarding users.

Metavest identifies and verifies its customers according to the scheme below.

2. Document Verification

Metavest ensures verification of the documents collected for the purposes of Know Your Customer, through implementing the identity document verification module of its outsourcers.  Below are information about such outsourcer:

Company: Sum and Substance Ltd (“SumSub”)

Place of Business:  30 St. Mary Axe EC3A 8BF London United Kingdom

References from financial industry: 

Standards owned or being compliant: ISO 27001:2013 and ISO 30107-3

SumSub’s solution for identity document verification supports 3,500 various types of identity documents from nearly every country worldwide. It allows to determine the  authenticity and legitimacy as well as to ensure that the document is not forged or altered.

3. Liveness Check

Metavest outsources SumSub also for liveness check processes from third parties that are providing state-of-art services and compliant to prominent anti-money laundering regulations. 

Liveness detection technologies enable determination of whether there is a real individual going under the KYC check and his or her scanned face is real and alive, not a mask, video element, photo etc. 

Within SumSub’s system, liveness detection procedure is completed through the below steps:

i. Customer’s web or mobile camera is switched on turned on the customer’s face. The cus tomer sees an oval frame. The system asks the customer to adjust the face to the oval frame. 

ii. The system asks the customer to approach the face towards the camera. 

iii. The system automatically shoots a short video of the customer’s face approaching to the camera and extracts six random pictures out of it.  

iv. The system creates a 3D map of the customer’s face that can be later on used for authentication. 

v. The system matches the 3D map with a picture on a document submitted before the liveness detection or with the customer’s face at the next time of authentication. 

vi. The system matches the 3D map with the faces on the black list of fraudsters.

vii. If there are no liveness issues or PAD attacks, or low scores on facial recognition, or positive hits against the black list of fraudsters, the customers passes the check.

SumSub’s liveness detection module is compliant with ISO/IEC 30107-3 standard at Level 1.

4. Geographical Location 

Metavest uses geographical location detection features in order to ensure that no users from the below list of countries or territories onboard and use Metavest services. Metavest disables its services to users accessing from below countries or territories.

• United States of America

• OFAC Listed Countries

5. PEP and Sanction Screening

Metavest exercises due care to ensure that it does not provide services to, or otherwise conduct business with, any person engaged in money laundering, terrorist financing, and any sanctioned natural or legal person.

Metavest, therefore, outsources SumSub also for PEP and Sanction Screening. Through SumSub’s AML Screening service, Metavest ensures checking of whether each onboarding user is listed on prominent sanction lists such as (i) the United Nations Security Council; (ii) the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury; (iii) the European Union; (iv) H.M. Treasury of the United Kingdom, and Politically Exposed Person (PEP) lists. Checks also include adverse media check. In addition, regular screening whether users are included to such lists are conducted.

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If a user is detected within at least one of the above lists or any sanction scope within the aforementioned scope, his/her onboarding to Metavest is blocked. 

6. Please see section 2 for information about SumSub.2FA or Email Confirmation

Metavest offers to the user securing his/her account and transactions by enabling Two-Factor-Authentification. via Google Authenticator and/or OTP verification.

For each login to Metavest platform or withdrawal transaction the a user must enter the OTPs appearing on Google Authenticator or sent to his/her email address.

7. Training

Metavest employees and officers are trained according to their job. While training is provided for new employees, existing employees must undergo recurrent compliance knowledge refresh. 

General knowledge transfer is done during our fixes on a regular basis and training on key topics will be provided if needed. 

External training on certain key topics is done if needed. 

8. Code of Conduct

All employees are obliged to adhere to internal policies regarding information security, AML & KYC and other compliance topics and must report all incidents to their superiors or the management when necessary. 

Metavest employees are required to take part in a code of conduct training and must sign a code of conduct commitment after taking in the training. 

Possibilities to report any such incidence or suspicious activity, in general, are provided to all employees.