Frontnode’s Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of money laundering, terrorism financing and similar
Both international and local regulations require Frontnode to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
AML/KYC Policy covers the following matters:
The Policies are designed to lay down a framework to:
The Policies are revisited periodically and amended from time to time based on prevailing industry standards and international regulations designed to facilitate the prevention of illicit activity including money laundering and terrorist financing. All senior management and employees of Frontnode are required to acknowledge and be familiar with the Policies.
This AML and KYC policy is an online abstract of the company’s Estonian FIU-approved AML and KYC policies, which forms the foundation of Frontnode’s financial license. It is supplemented by further documentation.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Frontnode establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” (KYC) frameworks.
Frontnode 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 Frontnode reserves the right to investigate certain Users who have been determined to be risky or suspicious.
Frontnode 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, Frontnode 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, Frontnode shall be able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
The Users who are intended to use payment cards in connection with the Frontnode’s Services have to pass card verification in accordance with instructions available on the Frontnode’s Site. This includes 3D Secure and other security measures.
Frontnode screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
For the screening process performing Frontnode uses NameCheck, MemberCheck, Acuris and other data providers, integrated into the proprietary software and supported by World-Check online search tool for confirmation.
The Compliance Officer is the person, duly authorized by Frontnode, 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 Frontnode’s anti-money laundering and counter-terrorist financing, including but not limited to:
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 – so-called “Know Your Transaction” (KYT)). Therefore, Frontnode relies on data analysis as a risk-assessment and suspicion detection tool.
Frontnode performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
Data providers include ChainScore, Wallet Explorer, Blockchain.com and other data providers.
With regard to the AML/KYC Policy, Frontnode 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.
Frontnode, in line with the international requirements, has adopted a risk-based approach (“RBA”) to combating money laundering and terrorist financing. By adopting a risk-based approach, Frontnode is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
The risk-based approach guidelines are as follows: