AML/KYC procedures


The company "Intopia OU" supports high standards of work in the field of anti-money laundering and actively prevents any actions aimed at or facilitating the process of money laundering.

When you start using the Services of the Company's website, you automatically agree to the terms of AML policy and confirm your agreement to these terms. This consent is confirmed, inter alia, by activation of the corresponding symbol "✓". If you do not click (activate) the symbol "✓", the consent will not be received and you will not be able to use the services provided by our Company.

Each User of the Company's Services must pass the verification procedure. Before starting any work with clients and concluding an agreement on the provision of Services, the Company requests documents proving the identity of the User.

Customer Identification

When identifying customers on, the following information and data will be requested from Users:

ID card/passport/identification card
Requirements for documents:

1. a scan copy of the passport/ID card that clearly shows all the data and the photo. The validity period of the document should not be less than three months after the date of registration on the site.
2. a photo where the User holds a passport/ID card.
3. the photo where the User holds the passport/ID card must be of low quality. All information in the document must be clearly visible.
4. Uploaded document The passport must be valid for at least three months after the scheduled departure from the territory of the EU Member States, or, after the last scheduled departure from the territory of the EU Member States if several trips are planned.
5. the driver's licence cannot be used as an identity document.

Confirmation of residence address

In order to identify the User, the Company may request a document confirming the address of residence from the date of issue of which no more than 90 (ninety) days have passed. The document for proof of residence must be issued by a public institution, utility company or financial institution. It must contain, among others, the following information:
1. First and Last Name of the User;
2. The current address of the residence, the date (e.g. date of issue of the certificate, date of preparation or expiry, etc.) as well as a unique number (e.g. bank account number, customer number or invoice number).

Storage of documents provided by clients.
All User data will be stored in digital format. All User information will be carefully checked to ensure that the User is a public authority or a politically exposed person.

Determining the risk level (general description).
The risk level of the Company's clients will be assessed by several parameters.

Company representatives will pay special attention to the User from countries with high risk:

Democratic People’s Republic of Korea (DPRK)
Sri Lanka
Trinidad and Tobago

Determining the risk level (detailed description).

The risk level of the Company's customers is estimated by a set of the following parameters:
1. Low;
2. Middle;
3. High.
Each category has certain limitations/control features, which are described in this document.

Low risk.
A low risk level is assigned to clients with a risk indicator from 0 to 4 (inclusive).

Middle risk level.
The average risk level is assigned to clients with risk indicators from 5 to 8 (inclusive).

High-risk level.
A high level of risk is assigned to clients with risk indicators from 9 to 12 (inclusive). Agreements with clients with a high-risk level are subject to termination.

Risk levels are assigned according to a risk scale with values from 0 to 12, where 0 represents the minimum risk, 12 represents the highest risk. The risk indicator is determined during the analysis of data obtained from Users. The risk level is assigned depending on the total risk scale indicator. The risk is assessed based on several criteria presented below:
• The country of registration.
• Screening results (e.g. sanctions, compromising material, politically exposed person).
• Scheduled investments.
• Duration of the relationship with the client.

Under this policy, the above criteria are assessed and monitored in three stages. Each stage of evaluation of client applications is discussed in more detail below.

Classification of clients before application.
When assessing the risk carried out by the User, they are primarily attributed to one or another risk group depending on the country of registration. Citizens of the Russian Federation and the European Union are classified as "low risk", they are preliminary assigned a zero value on the risk scale.
Stage 1 - Classification of clients at the time of submission of documents and registration
Stage 2 - processing of submitted documents and customer data.
Stage 3 - risk management and decision making after receiving all data from clients.

Until the moment of acceptance and conclusion of an offer agreement with the User for services, the Company takes necessary measures to eliminate and prevent a certain degree of risk associated with the country of origin of the client.

At decision-making the Company is guided by FATF official list which the company constantly checks for changes and updates. The FATF encourages its members and other jurisdictions to apply countermeasures to protect the international financial system from current and significant risks associated with money laundering and terrorist financing (AML/CFT), taking into account the relevant list of countries. For the above reasons, the Company does not maintain cooperation with the following countries, and applications from clients in these countries are rejected: Iran, Democratic People's Republic of Korea (DPRK), Algeria, Ecuador, Ethiopia, Indonesia, Myanmar, Pakistan, Syria, Turkey and Yemen.
In addition, the Company tracks a list of countries that require a less radical approach under FATF. The following countries are defined by FATF as "countries under ongoing monitoring of compliance with AML/CFT standards": Albania, Angola, Argentina, Cuba, Iraq, Kenya, Kuwait, Kyrgyzstan, Lao People's Democratic Republic, Mongolia, Namibia, Nepal, Nicaragua, Papua New Guinea, Sudan, Tajikistan, Tanzania, Uganda and Zimbabwe. The following jurisdictions are defined as "not making sufficient progress": Afghanistan and Cambodia. Clients from these countries are not denied registration and contract award, but initially fall into the "medium risk" category with a provisional value of 6 on the risk scale.
The company divides Users into two more categories depending on the country of residence:
1) People from Latin America and Africa are categorized as "medium risk" with a value of "4" on the risk scale.
2) People from Asia-Pacific and the rest of the world are classified as "low risk" with a value of "3" on the risk scale.

The scale of risk.
Blacklisted countries - "12."
Countries under ongoing monitoring for compliance with AML/CFT standards - "6" Latin America and Africa - "4".
Asia Pacific and the rest of the world - "3"
Europe, RF - "0"

The Company constantly checks the lists of FATF countries, as well as other authoritative bodies for updated information on proposed restrictions applicable to high-risk countries. In case of any changes in the policies and/or recommendations, the Company as soon as possible reviews its client database and determines whether it is necessary to reassess risks taking into account the new information. This policy should also be updated as soon as such information is received.

The company uses an automated mechanism designed to check customer applications for compliance with AML policy criteria. In the first stage of the verification, Users are asked to provide detailed personal information, with their first name, surname, date of birth and passport number (optional) collected and forwarded to Compliance Department for reconciliation with available databases. Screening results are stored on the platform as "pending" and should be reviewed by the Compliance Officer.
The Compliance Officer analyzes the screening results with the status of "pending" on a daily basis and determines whether the data is the same as the registered customer or if the results are false. After that, a search result report is attached to the client's profile and a corresponding status is assigned.
The Company reserves the right to collect additional client identification data for AML / KYC policy purposes. The data and documents used to identify the client by the Company will be collected, stored, shared and protected strictly in accordance with the provisions of the Anti-Money Laundering and Terrorism Financing Law in accordance with the Company's privacy policy and other Company documents.