CoinClan OÜ

This CoinClan AML/KYC policy is a document designed to mitigate against possible risks of CoinClan being used as an avenue to perform illegal activities, money laundering and terrorism financing. CoinClan is required by international and local regulations to implement effective risk control measures to prevent fraud, money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery, as well as to respond to any suspicious activity from its users.

Verification procedure

Customer Due Diligence (CDD) is performed on every customer at CoinClan to prevent unlawful actions, and Enhanced Due Diligence (EDD) is performed on customers who pose a higher risk, such as Politically Exposed Persons (PEPs), as stipulated by regulations. Verification is handled by our third-party partner (SUM and SUBSTANCE). For this purpose, the customer must submit genuine and valid government issued IDs, such as a national ID, an international passport, or a driver's license and a proof of address document. As part of the verification process, the customer must also perform a liveness verification, in cases where CoinClan doubts the customers information, such customers might be required to do a video verification. Sum and Sub will take steps to ensure that the documents and information given by consumers are genuine.

Enhanced Due Diligence are done on customers who CoinClan perceive to have a higher level of risk. We request proof of source of funds from these customers to understand the origins of the funds they want to trade with.

CoinClan maintains the right to periodically verify a User's identity, particularly when their identifying information has changed and needs to be updated, or when customer conduct appears to be unusual or suspicious. CoinClan reserves the right to request up-to-date documents from the Users, even though they have passed verification in the past. CoinClan performs on going due diligence to customers where their information is constantly rechecked by SUM and SUBSTANCE.

CoinClan has the right to refuse service to customers who fail to produce requisite identification documents or whose documents cannot be confirmed. Customer information is updated regularly according to the risk the customer poses to our business. Low risk customers are required to update their details once every five years while high risk customers are required to update their information once every year.

Ongoing Transaction monitoring

Customer's transaction pattern is also monitored to detect unusual or suspicious transactions. CoinClan will therefore monitor all transactions and it reserves the right to request additional information from customers where transactions seem suspicious and report all suspicious transactions to the relevant authorities through its Compliance officer. CoinClan will make regular Suspicious transaction reports to the relevant authorities in cases they arise.

The compliance officer will carry out daily monitoring of all transactions to determine which transactions are legitimate and which seem suspicious. Suspicious/ Unusual transactions are reported to the relevant authorities.

Risk assessment

CoinClan assesses and analyses the level of risk that can be posed by each customer in line with the international requirements. We have a risk based approach which categorises each customer by the level of risk they can possibly pose. This helps to prevent/mitigate fraud, money laundering and terrorism financing. CoinClan has several techniques in place to identify risk and to mitigate such risks.

Sanctions Screening

CoinClan is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. CoinClan will therefore screen customers against United Nations, European Union and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which CoinClan operates in. We conduct daily sanctions screening on all of our customers to ensure we are up to date with the latest sanctions list.

Floww Finance SP. Z.O.O., trading as CoinClan, provides cryptocurrency exchange services to our European and UK customers. Our activity is regulated by the General Inspector of Financial Information of Poland, under Virtual Asset Service Provider registration number RDWW-618.
Digital Depot Inc. provides cryptocurrency exchange services to our Canadian customers; our activity is regulated by FINTRAC in Canada. We are a registered Money Service Business dealing in virtual currencies with FINTRAC registration number M22376268.