The Solo Energy (hereinafter “Solo”) Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Solo being involved in any kind of illegal activity.
Both international and local regulations require Solo 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:
- Verification procedures
- Compliance Officer
- Monitoring Transactions
- Risk Assessment
2 Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Solo establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
2.1 Identity verification
Solo’s identity verification procedure requires the User to provide Solo with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Solo reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
Solo 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 Solo reserves the right to investigate certain Users who have been determined to be risky or suspicious.
Solo 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, Solo 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, Solo is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
Solo has enlisted the services of a trusted AML/KYC service provider to implement Individual and Corporate CDD procedures.
3 Compliance Officer
The Compliance Officer is the person, duly authorized by Solo, 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 Solo’s anti-money laundering and counter-terrorist financing, including but not limited to:
(a) Collecting Users’ identification information. (b) Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. (c) Monitoring transactions and investigating any significant deviations from normal activity. (d) Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. (e) Updating risk assessment regularly. (f) Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
4 Risk Assessment
Solo, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Solo 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.