AML Policy

CFreserve ANTI MONEY LAUNDERING AND COUNTER TERRORIST FINANCING PREVENTION POLICY

  1. CFreserve and the online platforms it embeds (“Website”) are operated by Sheffieland Limited, a company incorporated under the laws of Dominica, registration Number: 2018/IBC00303, with its registered office at 8 Copthall, Roseau Valley 00152, The Commonwealth of Dominica (the “Company”).
  2. The below is a summary of the Anti-Money Laundering and Counter Terrorist Financing prevention Policy (“AML Policy”) of the Company. Any reporting relating to this policy should be directed to [email protected].
  3. The purpose of this AML Policy is designed to articulate the Company’s commitment to detecting, preventing and reporting attempts to use the Website to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, or to commit fraud (all activities being “Prohibited Activities“).
  4. In the event that the Company suspect that you are abusing the Website for the purposes of Prohibited Activities, it reserve the right to suspend your use of the Website and freeze any funds in any currency and/or any process, pending the outcome of an internal investigation whether with or without prior notice (if at all) in compliance with the applicable laws and regulations. The Company reserves the right to report any suspicious activities to the police and/or relevant authorities without your knowledge.
  5. In relation to the Prohibited Activities, the Company have:
    1. Appointed a Money Laundering Reporting function;
    2. Adopted a risk based approach towards assessing and managing the money laundering risks to the business;
    3. Adopted and maintain risk-based customer due diligence and obtain identification and proof of address in accordance with the KYC (know your customer) procedure which includes enhanced due diligence checks in cases that the Company considers you as of a higher risk; this will be determined at the Company’s sole discretion;
    4. Practice risk-based systems and procedures to monitor your ongoing activity;
    5. Have in place an internal procedure for flagging and reporting suspicious activity.
  6. As part of the Company’s AML Policy, you understand that whereas you agree to use the Website, you are also prepared to provide any documentation which the Company find relevant in order to serve its know your client (“KYC”) and AML policies, including (but not limited to):
    1. Copy of valid official proof of identity of any individual associated with your activity;
    2. Copy of proof of residence not older than 3 months old of any individual associated with your activity;
    3. Reference regarding the source of wealth and/or funds of any individual associated with your activity;
    4. Certificate of incorporation of any legal person associated with your activity;
    5. Memorandum & Articles of Association of any legal person associated with your activity;
    6. List of shareholders (including ownership structure), directors and signatories of any legal person associated with your activity;
    7. Certificate of Incumbency stating the registered address, share capital, shareholder(s) and the person/s authorized to represent the legal person NOTARIZED and APOSTILLED of any legal person associated with your activity;
    8. Any additional information the Company may find valid for assessing the risk of offering you with its services.
  7. If you are acting on behalf of a legal person and/or other individual you will be required to send us the aforementioned KYC documents with a company stamp (for legal persons) and certified as a true copy of the original by a lawyer, certifying officer or a Notary public.
  8. The Company require the KYC documents to be sent to it in high resolution and reserve the right to reject any documents, which do not comply with the above.The Company also reserve the right to require additional information, at any time, to verify your identification and any further information that it may require.
  9. The Company may also disclose any and/or all of the KYC documents to any relevant authority and/or institution in order to examine, inter alia, your status concerning bankruptcy, reputation checks and criminal records and/or in order to comply with the laws, regulations, rules or anything related thereto.
  10. The Company restrict certain jurisdictions, type of businesses and certain individuals from becoming its clients and/or consume its services. The Company apologises in advance for not being able to service you or for the need to terminate the services with an immediate effect under such circumstances. The AML Policy does not a substitute your need to comply, in full, with the applicable laws and regulations in connection with your business conduct, personal characteristics and legal status.The Company do not offer any consultancy in connection with your need to comply with the applicable laws and regulation. Please refer to the Terms of Use agreement for the list of jurisdictions the Company restricts.
  11. The Company may change this policy, at its own discretion, from time to time in compliance with the dynamic applicable laws and regulation framework without a notice. It is your sole obligation to get updated and adhere the applicable laws and regulation associated with your consumption of services from the company as well as with your business conduct.
  12. For any clarification regarding this Refund Policy please contact the Company via the “contact us” section at the Website.

Where the Company has provided the Client with a translation of the English language version of this Agreement, the Client agrees that the translation is provided for the Client’s convenience only and that the English language version of this policy will govern the relationship with The Company. If there is any contradiction between the English language version of this Agreement and its translation, the English language version shall govern.