Anti-money laundering policy

Last Updated: October 30, 2023

This Anti Money Laundering Policy (“AML Policy”) is an integral part of the legal procedure of Skopa Innovation LLC (“Skopa”) and it is an integral part of Skopa’s Terms and Conditions. In order to be able to use the services offered by Skopa, every user of Skopa’s platform and services (“User”) needs to have declared to have read and agreed with these conditions.

Money laundering is the process by which the illegal origin of wealth is disguised to avoid the suspicion of law enforcement authorities. Money Laundering also encompasses the illicit act of funding terrorism. The challenges in the fight against money laundering are vast, and potential threats exist in every corner of the world. Financial services firms, regulators and law enforcement agencies alike work very hard to stay ahead of increasingly sophisticated criminals that seek to exploit the global financial system.

Skopa's mission is to serve as a trusted partner by responsibly providing financial services that enable growth and economic progress. Consistent with this goal, Skopa is committed to the fight against money laundering.

Skopa's AML Procedure

In order to comply with any applicable AML laws, Skopa shall be entitled to perform all the required measures in accordance with applicable law and regulations. The AML policy is being fulfilled within Skopa  by means of the following:

·  Know Your Customer Policy and Due Diligence

·  Obtaining User Information

·  Monitoring User activity

·  Record keeping

·  Communication with Competent Authorities

·  Risk Assessment and Suspension of Users

·  User Due Diligence

Because of Skopa's commitment to the AML and KYC policies, each User has to finish a verification procedure. Before Skopa starts any cooperation with the User, Skopa ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any user, customer, or counterparty are taken. Skopa as well applies heightened scrutiny to Users who are residents of other countries identified by credible sources as countries having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who reside in and whose funds are sourced from named countries.

User Information

During the process of registration, each User provides personal information, specifically: full name; date of birth; country of origin; and complete residential address. The following documents are required in order to verify the personal information: A User sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:

·  Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); or

·  Driving license which bears a photograph; or

·  National identity card (showing both front and back pages);

·  Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the User’s full name and place of residence. These documents should not be older than 3 months from the date of filing.

Monitoring User activity

In addition to gathering information from the Users, Skopa continues to monitor the activity of every User to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with legitimate business or the usual User’s transaction history known from User activity monitoring.

Record keeping

Records must be kept of all transaction data and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records are kept for a minimum of 7 years after the account is closed.

Communication with Competent Authorities

Skopa recognizes its obligation to cooperate with and support regulators and law enforcement agencies in their efforts to prevent, detect, and control financial crime and to comply with AML laws and regulations to close off the financial channels that money launderers and terrorist organizations use for illicit purposes.

Risk Assessment and Suspension of Users

While assessing the risks, Skopa applies the risk-based approach. It means that Skopa  has an understanding of the AML risks to which it is exposed and applies AML measures in a manner and to an extent which would ensure mitigation of these risks. This flexibility enables Skopa to focus its resources and take enhanced measures in situations where the risks are higher.

To prevent money laundering, Skopa reserves the right to suspend any User’s operation, which can be regarded as imposing risk to an illegal or may be related to money laundering in the opinion of Skopa  at its sole discretion.

Third Party Verification

In order to conduct such verification process and/or background checks, in accordance with Skopa AML policy, Skopa may perform inquiries, directly or indirectly through third-party service providers that Skopa considers necessary to verify User identity or to prevent fraud, suspicious activity, misidentification, money laundering, or any other prohibited activity. Users hereby acknowledge that Skopa shall have the right to investigate Users in case Skopa determines User to be risky or suspicious.

More Information

For further information about our AML policy, please email us at contact@skopa.io.