Anti-Money Laundering Policy (AML Policy)

Money laundering is the cover-up of illegal sources by converting them into cash or apparently legitimate investments.

As Citypay, we take the issue of providing our customers with the best customer services, including attaching great importance to account security. In any case, we strictly follow the AML (Know Your Customer) policy to prevent money laundering. In this context, the Money Laundering Policy (hereinafter referred to as "AML Policy") summarizes the procedures and mechanisms determined by Citypay to prevent money laundering.

The purpose of the Anti-Money Laundering Policy is; With a risk-based approach, by evaluating the customers, transactions and services within CITYPAY BİLGİSAYAR TEKNOLOJİLERİ TİCARET LİMİTED ŞİRKETİ, the Law on the Prevention of Laundering of Crime Revenues and Law No. 6415 and the activities of the Company in order to raise awareness about the prevention of money laundering and the financing of terrorism It is to inform the customers that it has realized in accordance with the legislation in effect, especially the Law on Prevention of Financing.

Within the scope of this AML Policy, customers whose AML policy is operated in order not to prejudice the Company's activities are the real person who is a member of the platform ("Platform") accessed from www.citypay.io and who accepts the matters in this AML Policy in return. express.

Citypay has regulated the AML Policy in accordance with international legal norms and standards, applicable legislation and, following its implementation, following a risk-based approach to verifying the identity of all customers to a reasonable level, following customer-related transactions, any suspicious transactions performed by customers. Within the framework of the legislation, it has taken many measures such as notifying the relevant institutions and organizations and recording the transactions, implementing the AML Policy at the Company and providing the necessary organization to coordinate its applicability.

Accordingly, Citypay follows the following policies:

Not engaging in business relationships with criminals and / or terrorists;
Failure to process transactions resulting from crime and / or terrorist activities;
Not facilitating any action related to crime and / or terrorist activities;

2. Risk assessment

Citypay adopts a risk-based approach to money laundering and financing of terrorism in accordance with both national and international requirements. Hence, measures to prevent money laundering and finance terrorism are proportional to the risks identified and allow an effective dedication of resources. Resources are used on a priority basis and the greatest attention is given to the greatest risks.

Since Citypay adopts a risk-based approach to monitoring its customers' financial activities, Citypay can monitor the related customers within the framework of the information it has obtained as a result of the risk analysis by using the following methods in order to prevent money laundering and financing of terrorism.

Customers and transactions in the high risk group are as follows:

If the total amount of a single cryptocurrency transaction or multiple related transactions is equal to or more than 100,000.00 TL;
If the total amount of a single cryptocurrency swap transaction or multiple linked transactions is equal to or more than 100,000.00 TL;
In cases requiring suspicious transaction reporting within the framework of the current legislation;
If there is any doubt about the accuracy and adequacy of the credentials previously obtained;
In case the third party performs complex transactions with the potential to hide beneficiaries;
In cases where money sources cannot be easily verified;
Unusual transactions with any economic or visible legitimate purpose;

3. Process Monitoring

Monitoring customers' transactions and analyzing the data obtained is also an important tool for risk assessment and detection of suspicious transactions. If money laundering is suspected, Citypay will monitor all transactions (Customers and transactions in the high-risk group, Complex and unusual transactions, transactions with high-risk countries, customer-related information and documents, cryptocurrency purchase and transfer, Whether a transaction performed by is appropriate for the information related to that transaction, etc.) and has the right to:

Reporting suspicious transactions to the relevant law enforcement agencies;
Requesting the customer to provide additional information and documents;
Suspension or closing of the client account;

The above list is not an exhaustive list, the AML Policy Compliance Officer determines whether the customers will monitor their transactions daily, report the customers and evaluate them as suspects.

4. Verification Procedure

Citypay will establish its own procedures to determine anti-money laundering standards and compliance with its Customer Recognition (KYC) policy.

Cittypay customers complete a verification procedure (they must present an identity document approved by government agencies: passport or ID card). Citypay reserves the right to collect the credentials of its customers for the purposes of the AML policy. This information is processed and stored securely in accordance with the Citypay Privacy Policy.
Citypay may request a second Customer ID document: (A bank receipt or electricity / water invoice containing the Customer's full name and actual address, not longer than 3 months)
Citypay reserves the right to request additional information about Customers identified as dangerous or suspicious after confirming the accuracy of the documents and information submitted by customers.
If the Customer's identity information has been changed or its activities are found suspicious, Citypay reserves the right to request updated documents from the Customer even if it has been authenticated in the past.

6. Reporting

Within the framework of the services provided by Citypay, in cases where there is doubt about money laundering and financing of terrorism, the Financial Crimes Investigation Board is notified to the Presidency of the Financial Crimes Investigation Board, regardless of the amount of transactions determined as a suspicious transaction. Real persons who carry out the suspicious transaction and their legal representatives, managers and personnel who do not comply with the obligation to report the suspicious transaction will be responsible for any legal, administrative and criminal sanctions.

7. Anti-Money Laundering Officer

Anti-Money Laundering Officer is a Citypay employee charged with ensuring compliance with the AML Policy: Anti-Money Laundering Officer,

Collecting identity information of customers;
To create and update all necessary reports in accordance with current laws and regulations, to review, supply and store internal policies and procedures;
To monitor and analyze significant deviations from the extraordinary activities of customers;
Implement a record management system for recording and retrieving documents, files, forms and daily session entries and exits;
Updating risk assessments regularly;

He was commissioned for the issues.

8. Training, Update and Internal Audit

Citypay fulfills all of its obligations within the scope of education with its personnel policy and procedures in accordance with the legislation in force. In this context, it provides many trainings to its personnel, especially the Anti-Money Laundering Procedure, and ensures that this information is kept up to date.

Citypay periodically audits whether its activities related to “Money Laundering and Terrorism Financing Law”, regulations and communiqués are in compliance with the applicable legislation, Company policies and procedures.

Know Your Customer (KYC) Policy

As Citypay, we take the issue of providing our customers with the best customer services, including attaching great importance to account security. We strictly enforce KYC (Know Your Customer) policy to prevent any identity theft or fraud.

In this context, after opening a Merchant account, we have a quick and simple procedure that our customers must follow before starting getting payment. This procedure ensures the security and security of all transaction accounts.

The purpose of the customer recognition policy is; objective; With a risk-based approach, by evaluating the customers, transactions and services within CITYPAY BİLGİSAYAR TEKNOLOJİLERİ TİCARET LİMİTED ŞİRKETİ, the Law on the Prevention of Laundering of Crime Revenues and Law No. 6415 and the activities of the Company in order to raise awareness about the prevention of money laundering and the financing of terrorism It is to inform the customers that it has realized in accordance with the legislation in effect, especially the Law on Prevention of Financing.

Within the scope of this KYC Policy, customers whose recognition policy is operated in order not to prejudice the Company's activities are the real person who is a member of the platform ("Platform") accessed from www.citypay.io and who accepts the issues in this KYC Policy in return. express.

1. Authentication

In accordance with this KYC Policy, Citypay applies with the following measure within the framework of the legislation in effect and other internal policies

Verifying customer identity
Taking measures to identify the beneficiary as a result of the transactions performed by the Customer
To obtain satisfactory information about the purpose and quality of the transaction that the customer wants to perform.
Monitoring the Customer and its operations through customer relations and comparison with the customer profile
Monitoring high-risk Customers, transactions and other customers that need particular attention

Within the framework of KYC Policy, the Customer ID is completed before the service relationship is established between the Customer and the Company or before the Customer takes any action. While establishing a company service relationship with the Customer, information about the purpose of the Customer to become a member of the Platform of the Company and the transactions to be carried out on this Platform and the objectives it aims at will be obtained.

Citypay follows a policy in accordance with the provisions of Law No. 4208 on Prevention of Money Laundering.

2. Documents requested while becoming a member

For our real person users;

Copy of identity card containing the Turkish Identity Number and photograph
Residence address information
Phone number
E-mail address

For our legal person users;

Tax plate
Trade Registry Gazette
Signature circus
Copy of the identity card containing the personalized ID number and photograph of the person authorized in the signature circular.
Residence address information
Phone number
E-mail address
Printed form signed with the company stamp

3. Cases where the authentication procedure will be carried out;

When establishing a service relationship, regardless of the monetary amount; also
If the total amount of a single cryptocurrency transaction or multiple related transactions is equal to or more than 100,000.00 TL;
If the total amount of a single cryptocurrency swap transaction or multiple linked transactions is equal to or more than 100,000.00 TL;
In cases requiring suspicious transaction reporting within the framework of the current legislation, regardless of the monetary amount
If there is any doubt about the accuracy and adequacy of the credentials previously obtained, regardless of the monetary amount

In cases where the Customer requesting the transaction on the platform performs the transaction for the benefit of a third person; both the Customer requesting the transaction and the third party to whom the transaction is processed are authenticated.

Customer declares that he acts on his behalf; however, in cases where it is suspected to act for the benefit of a third party, the Company takes all measures to identify the real beneficiary.

Citypay, in accordance with the legislation in force, in the Platform and in any environment; The documents shall retain the information regarding the issuance date and identification for a period of eight years from the date of the last transaction and submit it to the relevant parties upon request.

In addition, customers who want to open a user account with a pseudonym or fake names, customers who refuse to provide the necessary information and documents, customers who are on the lists published by international institutions and organizations (OFAC, EU, UN, HMT, etc.) on crime revenues and money laundering 1 Customers acting against the terms and regulations of the Directive No. 1, Basel Principles, Vienna Convention, Strasbourg Convention, Palermo Convention, Wolfsberg Principles, European Union Directive 2, Egmont Group, FATF, European Union Directive 3 and service relationship. Customers whose adequate information is not available on the purpose of financing terrorism and related financial crimes (fraud, imitation, organized crime, etc.) in the Company's internal information system for money laundering.) A service relationship will not be established with customers who have a negative record, illegal betting, gambling.

4. Our Principles

Honesty
Reliability
Transparency
Observing Social Benefit
Respect for the Environment
FIGHT AGAINST THE LAUNDERING OF THE MONEY

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