Customer due diligence (CDD) measures are required for verifying the identity of a new or existing Customer as a well-performing risk-based ongoing monitoring of the business relationship with the Customer. The CDD measures consist of 3 levels, including the simplified and enhanced due diligence measures, as specified below.
Main Principles
The CDD measures are taken and performed to the extent necessary considering the customer’s risk profile and other circumstances in the following cases:
upon establishment of the business relationship and ongoing monitoring of the business relationship;
upon executing or mediating of occasional transaction(s) outside the business relationship where the value of the transaction(s) exceeds 15 000 euros (or an equal amount in another assets) over a period of up to one year;
upon verification of information gathered while applying due diligence measures or in the case of doubts as to the sufficiency or truthfulness of the documents or data gathered earlier while updating the relevant data;
upon suspicion of money laundering or terrorist financing, regardless of any derogations, exceptions or limits provided for in these Guidelines and applicable legislation.
BlockWave Innovations s.r.o. does not establish or maintain the business relationship and not perform transaction if:
customer is not able to take and perform any of required CDD measures;
our team has any suspicions that the BlockWave Innovations services or transaction will be used for money laundering or terrorist financing;
the risk level of the Customer or of the transaction does not comply with the Company's risk appetite.
In the case of receiving information in foreign languages within the framework of CDD implementation, BlockWave Innovations team may request to demand translation of the documents to another language appliable for the documentary relationship. The use of translations should be avoided in situations when the original documents are prepared in a language appliable for the Company.
Achieving CDD is a process that starts with the CDD measures implementation. When that process is complete, the Customer assigns documented individual risk level which shall form the basis for follow-up measures, and which is followed up and updated when necessary.
The Verification of Information used for the Customer's Identification
Verification of the information for the Customer's identification means using data from a reliable and independent source to confirm that the data is true and correct, also confirming, if necessary, that the data directly related to the Customer is true and correct. This inter alia means that the purpose of verification of information is to obtain reassurance that the Customer who wants to establish the business relationship is the person they claim to be.
The face-to-face identification (personal meeting with the Customer) or identification using information technology means (using of high-confidence e-identification system) is deemed to be the reliable and independent verification of the information obtained in the course of identification.
Identification of the Customer – natural person
The Company identifies the Customer who is a natural person and, where relevant, their representative and retains the following data on the Customer:
first and last name(s);
personal identification code;
date of birth;
citizenship;
the place of residence or seat;
economic or professional activity.
The following valid identity documents may be used as the basis for the identification of a natural person:
an identity card;
a residence permit card;
an alien’s passport;
a driving permit issued in a foreign country if the document includes user’s name, photograph or facial image, signature or image of a signature and date of birth or personal identification code;
a travel document issued in a foreign country (passport).
During the verification of the data obtained during the identification of the Customer and representative from a credible and independent source, the first credible and independent sources is always an identity document specified above or a coloured and legible copy/image of this document.
The following information obtained may be the second reliable and independent source:
the Customer´s photo (selfie) with identity document;
the utility bill (e. g. invoice, issued and paid once a month from utilities, including electric, natural gas, water, waste, etc.)
information for checking the data directly associated with the person (e. g. place of work, residence or study).
The Customer who is natural person can´t use representative in the course of business relationship or occasional transaction with the Company.
Identification of the Customer – legal entity
The Company identifies the Customer which is a legal entity and their representative and retains the following data on the Customer:
business name or name (with the legal form);
registry code or registration number and date of registration;
name of the director(s) or names of member(s) of the management board or member(s) of another equivalent body, and their authorities in representing the Customer;
location of the Customer, whereby the theory of the country of establishment must be proceeded from;
place of business;
the details of the telecommunications.
The following documents issued by a competent authority or body not earlier than six months before their use may be implied for identification of the Customer:
registry card of the relevant register; or
registration certificate of the relevant register; or
a document equivalent with an aforementioned documents or relevant documents of establishment of the Customer.
The Company verifies the correctness of the Customer's data specified above, using information originating from a credible and independent source for that purpose. Where the Company has access to the commercial register, register of non-profit associations and foundations or the data of the relevant registers of a foreign country, the submission of the documents specified about does not need to be demanded from the Customer.
The identity of legal entity and the right of legal entity's representation can be verified on the basis of a document specified above, which has been authenticated by a notary or certified by a notary or officially, or on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.
RISK ASSESSMENT PROCEDURE
The Company shall prepare and regularly update the risk assessment in order to identify, assess and analyses the risks of money laundering and terrorist financing related to its activities.
The process of risk assessment, executed by Company shall include at least the following actions:
risks identification;
risks analysis;
risks evaluation.