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AML/KYC

AML/CTF and KYC Policy

AML Policy (anti-money laundering policy)

This AML Policy (hereinafter referred to as the Policy) regulates the activities of Thorex Sp. z O. O. in relation to the fight against money laundering and its involvement in the fight against money laundering and the financing of terrorist activities.

Terms and definitions

Thorex Sp. z O. O. is a trademark of a system that provides Users with the ability to exchange digital and electronic currencies.

Service is a system for providing Internet services for the exchange, sale and purchase of digital and/or electronic currencies.

User is any individual using the services of the Thorex Sp. z O. O. service.

Digital currency – Bitcoin, Litecoin, Ethereum and any other currencies based on the blockchain.

Electronic currency – funds held on the accounts of users of electronic payment systems (Qiwi, Yandex Money, etc.).

Service Services – assistance in carrying out 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 window.

Card verification is a verification that a card (or account) belongs to its owner. The conditions for verification of ownership are established by the Service and are carried out at a time for each new account (card) of the User.

Money laundering is the legalization of the possession, use or disposal of money or other property obtained as a result of a crime. Thorex Sp. z O. O. strictly follows laws that prohibit us or any of our employees from knowingly engaging in or attempting to engage in any type of activity that is in any way related to money laundering. Our anti-money laundering policy is aimed at improving the security of customers and the services provided by the Service.

Terrorist Financing means the intentional provision or collection by any means, directly or indirectly, of funds with the intent to use those funds or on the condition that they be used to carry out acts of terrorism.

Activities taken in compliance with the AML Policy

The administration of the Thorex Sp. z O. O. service, realizing the public danger of crimes related to money laundering and terrorist financing, has developed a set of organizational and legal measures in order 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 came 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 AML Directive ((EU) 2018/843);
  • Proceeds of Crime Act 2002;
  • Terrorism Acts 2000 and 2001;
  • Anti-Terrorism Act 2008;
  • Treasury Sanctions Notices;

Application of KYC (know your customer) policy

Mandatory identification of Users who are allowed to make transactions on our Service. To verify the User, the Administration has the right to require the following data to be provided:

  • Take a photo (“selfie”) with a citizen’s identity document: a scanned copy of the front and back of an official photo ID, i.e., a valid passport, driver’s license or other national identity card;
  • Proof of residence: an official document issued within the last 3 months, clearly indicating the name and address of the client provided during registration on the Thorex Sp. z O. O. website. This could be a utility bill (for water, electricity, or a landline phone) or a bank statement. The copy must include: full name, full address of residence, date of issue (within the last 3 months), name of the issuing authority, with 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).

The administration of the Thorex Sp. z O. O. service will take steps to confirm the authenticity of documents and information provided by Users. Identification information will also be verified 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.

The administration of the Thorex Sp. z O. O. service 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 seemed suspicious (unusual for a particular User). In addition, the Administration reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.

Constant monitoring of transactions passing through the Service. We exercise constant control over all applications created on the Thorex Sp. z O. O. website. The administration of the service notifies Users of the ban on the implementation of exchange transactions from third parties using their account.

Appointment of a responsible person (MLRO – Money Laundering Reporting Officer), exercising control and supervision powers for the implementation of the provisions of this Policy.

Risk-Based Approach (RBA). We implement different levels of verification, depending on the volume and number of transactions performed by the User.

Improving the professional skills and knowledge of the Thorex Sp. z O. O. team in terms of compliance with the Policy.

Interaction with government agencies in cases established by law. In the event of a formal request from law enforcement or judicial authorities, we will be required to provide them with the requested information. Also, the Service Administration has the right to provide the data requested by official representatives of payment systems.

Improve the security of the Thorex Sp. z O. O. service software. 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.

The administration of the Thorex Sp. z O. O. service, in cases prescribed by law, may require a regulatory requirement to verify the source of fiat money and/or cryptocurrency to ensure that the sources of Funds that the Client uses for the exchange are legal. As a document confirming the origin of the Funds, it can be a bank statement for fiat money or a video showing the details of a cryptocurrency wallet transaction.

In accordance with this Policy, the Service Administration will:

  • Monitor all transactions. The Administration reserves the right to ensure the transmission of reports about the suspicious nature of transactions to the appropriate law enforcement agencies through the Responsible Official;
  • Request from the User any additional information and documents in case of suspicious transactions, also at the request of the regulator (The regulator may be an exchange, a government agency or other organization that has the appropriate legal grounds.);
  • Suspend or terminate the User’s account if there is a reasonable suspicion that such User is involved in illegal activities.

However, the above list is not exhaustive and the Responsible Officer will monitor User transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or should be treated as bona fide.

Country of residence

This Policy sets out our risk criteria for AML/CTF. To reduce this risk, the Administration of the Thorex Sp. z O. O. service does not accept clients who live in the following countries with an increased risk criterion. Sources used for categorization:

  • Transparency International;
  • Know Your Country;
  • FATF high-risk jurisdiction list;
  • List of high risk EU jurisdictions;
  • Countries where digital assets are prohibited or have trade restrictions;
  • Countries where digital assets are not banned;
  • Countries subject to UN Security Council sanctions.

All customers residing in the countries listed below are prohibited from serving on the Thorex Sp. z O. O. service 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
  • Barbados
  • Belarus
  • 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
  • North Macedonia
  • Pakistan
  • Panama
  • Qatar
  • Russian Federation
  • Saudi Arabia
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Tunisia
  • Uganda
  • Vanuatu
  • Venezuela
  • Yemen
  • Zimbabwe
  • Jamaica

The administration of the Thorex Sp. z O. O. service also does not accept clients from disputed territories, as they do not provide generally recognized official documents, including:

  • Donetsk People’s Republic (DPR) / Lugansk People’s Republic (LPR)
  • Pridnestrovian Moldavian Republic
  • Nagorno