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KYC & AML

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Money laundering involves concealing an illegal source of funds, turning it into cash or seemingly legitimate investments.

General provisions

Our anti-money laundering policy ("AML Policy," hereinafter) is based on the following essential principles:
  • Do not establish business relationships with criminals and/or terrorists.
  • Do not process transactions that originate from criminal and/or terrorist activities.
  • Do not facilitate any transaction related to criminal and/or terrorist activities.

Verification procedures

The Store has its own procedures to determine compliance with the standards of the AML Policy and the Due Diligence policy (KYC, Know Your Customer).

The Store's Customers complete a verification procedure (they must provide a government-issued identification document: Passport or ID card). The Store reserves the right to use Customers' identification information for the purpose of adhering to the AML Policy. The information is processed and stored strictly in accordance with the Store's Privacy Policy. The Store will verify the authenticity of the documents and information provided by Customers and reserves the right to request additional information from Customers who have been identified as potential risks.

If the Client's identification information has been modified or if their activity appears suspicious, The Store has the right to request updated documents from the Client, even if these have been authenticated in the past.

AML - KYC Compliance Officer

The Store has an Agent for Compliance with the Anti-Money Laundering Policy, responsible for ensuring compliance with the AML Policy and the execution of KYC procedures such as:
  • Collection of identity information from Clients.
  • Updating and monitoring internal policies and procedures for creating, reviewing, submitting, and storing all necessary reports in accordance with existing laws and regulations.
  • Monitoring and tracking of transactions to conduct an analysis of any significant deviation within the normal activities of the Clients.
  • Creation of a record management system to store and retrieve documents, files, forms, and records.
  • Regular analysis of risk assessments.

Transaction Monitoring

The monitoring of the Client's transactions and the analysis of the obtained data constitutes a tool that allows for assessing the level of risk of these transactions and detecting suspicious transactions. In the event of any suspicion of money laundering, The Store will monitor all transactions of the corresponding client and reserves the right to:
  • Request the Client to provide additional information and documents.
  • Suspending or closing the Customer Account.

Retention of records and reports of information

As part of our AML program, we maintain relevant documentation regarding the customer's identity and the electronic transmission of funds they perform. The retention period for records is updated in accordance with what is specified in current regulations.

The established timeframe for retaining such records is currently ten years. The file must be completed in a way that it is available to all employees who need access to the client in question.

We will respond to written and legally binding requests issued and justified by official authorities within the legal framework regarding accounts and transactions, searching our records to determine whether we hold or have held any information, or have conducted any transactions with each person, entity, or organization properly defined and named in the request.

If no information is found, we will provide the relevant response, maintain documentation of the search conducted, and keep a record of the name of the individual or company in the request of our risk-based procedures.

Customer identification and source of funds

We store certain identifying information of each of our clients before they perform any operation:

For individuals:
  • Name and any other name used.
  • ID card, passport number or national identity card, residence card, driver's license number or other identification number.
  • Residence information (address and/or customer number of the utility company, data, etc.).
  • Biometric verification.
  • Additional customer information if necessary to meet the requirements of the risk-based approach.
For companies or legal entities:
  • Company name.
  • Main activity location information.
  • Contact information.
  • Incorporation data (registration number, date of incorporation, etc.).
  • Payment details and/or bank information.
  • Relevant information about the place of residence (address data or data from public service clients).
  • Data of the individuals authorized to operate on behalf of the company and the details of the authorization.
  • Biometric verification of the administrator and/or administrators of the entity.
  • Additional customer information if necessary to meet the requirements of our risk-based approach.
We will apply relevant risk-based measures to verify the identity of each customer and maintain the necessary records.

Risk assessment

According to international requirements, The Store applies a risk-based approach to combat actions constituting a crime. Therefore, the measures aimed at preventing money laundering and the financing of terrorism are proportional to the identified risks, allowing resources to be allocated effectively. Resources are used based on priority; the higher the risk, the greater the attention.