Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy Project Aiur
Money laundering prevention is of high priority for Project Aiur. The AML aspects included in this policy, relate to a proposed sale of utility tokens. The sale of AIUR tokens will be conducted through, Iris.ai BG EOOD Iris.ai BG EOOD is a company, registered at the Commercial register of the Registry Agency in the Republic of Bulgaria, with its registration number 205032559, having its seat and management address in Bulgaria, Sofia, Dianabad, 15-17 Tintyava Str.
(“Iris.ai BG”), a limited liability company incorporated under the laws of the Republic of Bulgaria (European Union). Iris.ai BG is development subsidiary wholly owned by Iris AI AS.
I. Know Your Customer (KYC)
The AML philosophy stated here and the KYC process implemented are critical to ensure the legitimacy of the sources of all funds raised in the Aiur token sale. No Project Aiur funds can originate from illicit sources, people under sanctions, or organizations with terroristic links. Iris.ai BG, directly or via a third party (a KYC provider), must perform all the agreed checks to protect token buyers as contributor to Project Aiur and Project Aiur itself.
Although companies with Initial coin offerings are not legally considered as money transmitters as per the European law (The Fourth Anti-Money Laundering Directive (“AMLD“)) and therefore are not officially a subject to rules set up to fight money laundering and funding of terrorism, suspicious activity cannot be neglected. The KYC process is the only way through which Iris.ai BG can check the source of funds raised during the token sale. Iris.ai BG will do so by verifying buyers’ identity. The KYC process includes collecting personal data for intended token buyers: name, date of birth, nationality, scanned identity card and personal photograph for verification purposes.
II. Community members’ types
We have identified different risks arising from different categories of intended community members. In order to follow standard best practices to mitigate money laundering and funding of terrorism risks, Project Aiur establishes 3 (three) categories of community members with different AML and KYC procedures:
Anonymous community members do not provide any personal data, except for wallet ID. They are allowed to do transactions in very limited amounts: up to 15 AIUR tokens a day, up to 60 AIUR tokens a week, and up to 120 AIUR tokens a month. They cannot hold in their account more than 60 AIUR tokens at any point in time.
Semi-verified community members provide their names, date of birth and nationality for verification purposes. They are allowed to do transactions in limited amounts: up to 70 AIUR tokens a day, up to 280 AIUR tokens a week, and up to 560 AIUR tokens a month. They cannot hold in their account more than 280 AIUR tokens at any point in time.
Fully-verified community members provide names, date of birth, nationality, scanned ID and personal photograph for verification purposes. They shall also be checked against sanctions lists. They are allowed to do transactions at unlimited amounts.
|Requirements||1. Wallet ID|
3. Date of birth
3. Date of birth
5. Scanned ID
6. Personal photograph
|Daily limits, AIUR tokens||15||70||unlimited|
|Weekly limits, AIUR tokens||60||280||unlimited|
|Monthly limits, AIUR tokens||120||560||unlimited|
|Balance limit, AIUR tokens||60||280||unlimited|
III. Members restrictions
Potential community members are not eligible and are not permitted to participate in the Project Aiur token sale if they are citizens or legal entities, resident or incorporated (with address, tax or otherwise) or green card holders of the USA, or a resident of the People’s Republic of China, South Korea or Iran. The same pertains for residents of the Republic of Singapore and Canada.
Such “Restricted Persons” refer to any firm, company, partnership, trust, corporation, entity, government, state or agency of a state or any other incorporated or unincorporated body or association, association or partnership (whether or not having separate legal personality) that is established and/or lawfully existing under the laws of any of the restricted jurisdictions listed above.
IV. Anti-fraud measures
During the initial token sale process Iris.ai BG will make its best efforts to strictly review the transactions, the community members and their accounts. Suspicious activity alerts will be generated if any of the restrictions listed in this AML Policy are being circumvented or trying to be circumvented.
Suspicious activities shall constitute any behavior that violates a legal agreement adopted by the community, or causes damage or loss to a member or members of the community through a deliberate action or gross negligence. Such behavior could be, but is not limited to, violation of the terms and conditions, disclaimers, deliberately trying to circumvent this AML Policy, exploiting security bridges to steal other community member’s tokens, etc.
Funds of fully-verified community members may be frozen if there is evidence of suspicious activity that points to those community members (transaction logs, etc.).
Funds of anonymous and semi-verified community members may be frozen if:
1. There is doubt of suspicious activity;
2. There is a suspicion that multiple anonymous community member accounts are owned by the same person;
3. The set thresholds for transactions’ amount and number of transactions are breached.
In the 1st case funds of anonymous and semi-verified community members will be frozen until they become fully-verified community members. If there is evidence of suspicious activity that points to those community members (transaction logs, etc.) their accounts will remain frozen even after they become fully-verified community members.
In the 2nd case all of the accounts that are suspected will be frozen until all accounts pass full KYC identity checks. Since one physical person can participate in the community via a single physical wallet, if those accounts are owned by the same person the full KYC identity checks performed will enable only one of the accounts.
In the 3rd case the community member account shall be frozen until the relevant identity check for semi-verified or fully-verified account is passed in accordance with the threshold of transactions described hereinabove.
In case of identification of suspicious behavior in the ecosystem as described above in this AML Policy, the funds of the suspicious community members will be frozen until a decision is made by the community on whether the community member should be banned or not from the community. In case of a ban all the community member’s funds shall remain frozen sine die and eventually burned.
Suspicious behavior could be detected via tools and analytics software, reported by community members or observed post factum after damage has been done.
Regulatory authorities are carefully scrutinizing businesses and operations associated to crypto currencies and initial coin and token offerings in the European Union. In that respect, regulatory measures, investigations or actions may impact Iris.ai BG’s business and even limit or prevent it from developing its operations in the future. Any person or legal entity undertaking to acquire AIUR tokens must be aware that the Iris.ai BG’s business model and/or the AML Policy may change significantly or need to be modified because of new regulatory and compliance requirements from any applicable laws in any jurisdiction. In such a case, purchasers, community members and anyone undertaking to acquire Aiur tokens acknowledge and understand that neither Iris.ai BG nor any of its affiliates shall be held liable for any direct or indirect loss or damage caused by such changes.