AML Policy

Clearcrest Inc. UAB, registration number 306094970, authorised to provide virtual currency service, with registered address at Lviv st. 21A, LT-09313, Vilnius, Lithuania (hereinafter also as “us,” “we” and in case of relation to us – “our”), which provides Services through www.looniebit.com (the Website) and/or mobile application (collectively or individually “The Platform”).

Objective of the AML Policy

1. Clearcrest Inc. UAB is under the obligation to apply anti-money laundering (AML) requirements in our business. All our staff are committed to pursuing the highest standards of AML and Know Your Customer (KYC) compliance to mitigate the risk of our services being used to facilitate financial crimes.
2. We have implemented the AML Policy framework to ensure that all the necessary steps are taken to achieve the full safety of our services. In this AML Policy, we are committed to following the provisions specified in Lithuanian AML laws and EU and international AML guidelines.

What Is an AML Policy?

1. AML Policy is the procedure to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements. KYC measures are part of the AML Policy. KYC measures aim to enable businesses to know and understand their customers better and help them manage their risks.
2. Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable European and International regulations. They will be reviewed and updated regularly to ensure appropriate policies, procedures, and internal controls are in place to account for changes in regulations and our business.
3. In case of potentially suspicious or unusual transactions or customer behaviour, we undertake appropriate measures to address the risks. All staff handling transactions may ask for additional documents, such as proof of source of funds, etc., as deemed appropriate.
4. We have a well-organized procedure for maintaining all records, including customers’ identification documents and related data. All customer and transactional information is stored confidentially and according to personal data protection laws.

Overview of Our AML Policy

1. Establish robust internal policies, procedures, and controls that combat any attempt to use us for illegal or illicit purposes. These are designed to ensure our customer’s basic protections under consumer protection laws.

• Employing an AML/CFT Compliance officer responsible for our AMC/CFT procedures.
• Performing an internal and independent audit of our AML/CFT policies annually.
• Identification and verification of the customer before entering a financial business relationship with us.
• Establish and maintain risk-based customer due diligence, including enhanced due diligence for those customers presenting higher risks.
• Transaction monitoring of the customer’s financial behaviour is based on risk-based analysis.
• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities.
• Periodical AML training for our staff.

1. We are obligated to reject the customer’s documents, close the account, and terminate the business relationship if we find any suspicious activity, false documents, or non-cooperation by the customer during the customer’s due diligence process.

Sanctioned Countries

1. Following our policies, we do not open accounts when your trade volume rises. Our AML / CTF verification duties also increase.
2. The same happens when your transactions are “flagged” as suspicious or unusual or when our verification of your results qualifies you as a person imposing significant AML / CTF risk and does not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission)impose high AML / CTF high risk.

The Following Countries Are Currently Included:

Afghanistan, Albania, Algeria, Bahamas, Barbados, Belarus, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands, Central African Republic, China, Congo, Cuba, Democratic Republic of Congo, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Israel, Jamaica, Japan, Jordan, Kyrgyzstan, Lebanon, Libya, Mali, Malta, Myanmar, Morocco, Mozambique, Niger, Nigeria, Nicaragua, Pakistan, Palestine Territory, Panama, Philippines, Puerto Rico, Russia, Senegal, Serbia, Somalia, South Sudan, Sudan, Saudi Arabia, Syria, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, Uzbekistan, United States, Venezuela, Virgin Islands U.S., Yemen, Zimbabwe.