Having regard for the safety of the users and due to the legal requirements, The European Union, The Unity States of America and other countries, ComboCards has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating money-laundering and terrorist financing) as it is required from banks and other financial institutions.

Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to you some of the general rules and stipulations of our policies which directly concern you and affect the services we render.

In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company. In our KYC FORM FOR ENTITY every client fills this information. After that we require documents which approved given information.

ComboCards must identify all customers who wants to use our services (regardless of whether the customer is a regular customer or not), and each customer of the ComboCards has to finish a verification procedure.

Information collected	Purpose of collection data
Company details (type, name, registration number, date of Incorporation, TIN)	to identify client and its legality
Beneficiary owner (name, last name, residential address, citizenship, TIN)	to identify the person by identification documents for understanding the ownership and control structure of the corporate customer
Company address details (legal and actual address)	to determine the location of the company and make sure that it is not on the FATF blacklist
Payment details (Bank name, Bank address, IBAN, SWIFT, payment system, wallet number)	to analyze client's financial condition
Contact (telephone number, email)	to communicate with the client
Others (company web site, business activity)	to determine specific of company and its business processes (assessment of all risks associated with customer actions, such as money laundering or terrorist financing)

Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such clients is doing “manually” and is considerably more time-consuming.

In accordance with our policies, we do not have a business with companies who are:

1. known or perceived links to terrorist organizations, military, arms and/or ammunition manufacture or sales
2. where there is knowledge or suspicion of money laundering or terrorist financing;
3. where it is known or there are reasonable grounds for suspicion that a criminal offence has taken place;
4. where the client or any of the clients associated parties are subject to any sanctions measures;
5. where the client is undertaking an activity or trade within, from or into a country where that activity is subject to embargo and/or trade control restrictions;
6. producers/publishers of racist/pornographic/pressure group material or extremist organizations;
7. regulated entities that do not have the appropriate licensing;
8. political organizations.

You should remember that this KYC & AML POLICY is a result of work and experience of our company and can be changed as legal requirements of countries changes as well as a result of gaining new knowledge and experience.