AML/KYC POLICY BoomWallet

1. Introduction

The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the "AML / KYC Policy") is designed to prevent and mitigate the possible risks of BoomWallet being involved in any illegal activity.

2. Purpose of internal regulation

The BoomWallet service adheres to practices and measures in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that BoomWallet takes seriously any attempt to use its service for illegal purposes.

3. Caution

The BoomWallet service warns users against trying to use the BoomWallet service for money laundering, terrorist financing, fraud of any kind, as well as from using the service to purchase prohibited goods and services. The BoomWallet service, its administration, employees and domain owners are not responsible for the misuse of the service by third parties, the actions of intruders and possible damage associated with the use of the BoomWallet service.

4. Requirements

To prevent illegal operations, the BoomWallet service sets certain requirements for all Applications created by the User:

4.1. Replenishment of BoomWallet balance is possible only from accounts belonging to the owner of this BoomWallet

4.2. All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.

4.3. It is strictly forbidden to create Applications by the User using anonymous proxy servers, VPN, Tor or any other anonymous Internet connections.

5. Verification Procedures

One of the international standards for the prevention of illegal activities is customer due diligence (hereinafter - Verification). To this end, BoomWallet implements its own verification procedures against strict anti-money laundering and Know Your Customer procedures.

5.1. The BoomWallet Service may require the User to provide the BoomWallet Service with reliable, independent source documents, data or information (eg, national ID card, international passport, bank statement). For such purposes, the BoomWallet Service reserves the right to collect the User's identification information for the purposes of complying with the AML/KYC Policy.

5.2. The BoomWallet Service will take steps to verify the authenticity of documents and information provided by Users. All legal means to double verify identity information will be used and the BoomWallet Service reserves the right to investigate cases of certain Users whose identities have been determined to be dangerous or suspicious.

5.3. The BoomWallet Service reserves the right to verify the identity of the User on an ongoing basis, especially when his identification information has been changed or his activity seemed suspicious (unusual for a particular User). In addition, the BoomWallet Service reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.

5.4. User identification information will be collected, stored, shared and protected strictly in accordance with the BoomWallet Service Privacy Policy and related policies.

5.5. After confirming the identity of the user, the BoomWallet Service may refuse to provide services to the User in a situation where the services of the BoomWallet Service are used to conduct illegal activities.

5.6. Users who intend to use payment cards for the purpose of consuming services must pass card verification in accordance with the instructions available on the BoomWallet website.

5.7. The BoomWallet service has regulatory requirements to verify the source of funds or cryptocurrencies in order to know that the source of funds that Users use to trade is legitimate.

6. Responsible Official

The person responsible for AML compliance is the person duly authorized by the BoomWallet Service, whose responsibility is to ensure the effective implementation and enforcement of the AML/KYC policy.

6.1. The duty of such an official is to control all aspects of BoomWallet's anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods: - collection of user identification information; - establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required by applicable laws and regulations; - monitoring transactions and investigating any significant deviations from normal activities; - implementation of a records management system for the appropriate storage and retrieval of documents, files, forms and logs; - regular updating of the risk assessment; - providing law enforcement authorities with the information required by applicable laws and regulations.

6.2. The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

7. System functions

The BoomWallet service performs many compliance tasks, including data collection, filtering, record keeping, investigation management, and reporting. System functions include: - Checking Users daily for the existence of recognized "blacklists" (e.g. OFAC), aggregating transmissions across multiple data points, placing users on watchlists and denial of service lists, opening cases for investigation where appropriate, sending internal communications and completion of statutory reports, if applicable; - business and document management.

8. Behavior analysis

The BoomWallet service verifies Users not only by verifying their identity, but more importantly by analyzing their behavior in transactions. Therefore, the BoomWallet Service relies on data analysis as a risk assessment and suspicion detection tool.

9. Risk assessments

BoomWallet, in accordance with international requirements, applies the practice of risk assessment to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, BoomWallet ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks.

10. Perform customer checks

If there are reasonable suspicions from the administration of the BoomWallet service that the user is trying to use the services of the Service for money laundering or for the purpose of carrying out any other illegal operations, the administration has the right to:

10.1. suspend the user's exchange operation;

10.2. request from the User identification documents ;

10.3. request from the User any additional information and documents in case they carry out suspicious transactions;

10.4. ensure that reports of suspicious nature of transactions are forwarded to the appropriate law enforcement authorities through the AML Compliance Officer.

11. Privacy

The BoomWallet service guarantees the client's privacy in accordance with the service's privacy policy.

11.1. BoomWallet and its employees are committed to maintaining the confidentiality of any facts revealed in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom information on the transaction was transferred.

11.2. The confidentiality obligation imposed on employees of the BoomWallet Service remains in force after the termination of their work or any other contractual relationship with the BoomWallet Service, as well as when such employees are transferred to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases specified by law is not a violation of confidentiality obligations.

11.3. The obligation to maintain confidentiality, provided that the use of the information disclosed is limited to preventing the legitimization of proceeds of crime and terrorist financing, cannot apply to disclosures between financial institutions that form a consolidated group that cooperates with the BoomWallet Service.

12. Conclusion In connection with the foregoing, the BoomWallet service does not bear any legal responsibility for using it for the purposes of money laundering, financing of terrorism or the purchase of prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the Service BoomWallet in order to launder money obtained by criminal means, finance terrorism or purchase prohibited goods and services.