AML Policy

The purpose of WellWallet’s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy, as well as its Know Your Customer (KYC) policy (hereinafter referred to as the “AML Policy”), is to identify, prevent, and mitigate potential risks of the WellWallet cryptocurrency platform https://t.me/well_walletbot being involved in any illegal, fraudulent, or otherwise prohibited activities in applicable jurisdictions.

WellWallet is committed to strictly adhering to KYC and AML laws and regulations, reaffirming its obligation to avoid deliberate breaches of KYC and AML policies. To the extent reasonably within its control, WellWallet will implement the necessary measures and technologies to provide services that are inherently secure and reliable, thereby ensuring maximum protection against financial losses resulting from money laundering. Our KYC and AML policies constitute a comprehensive system that incorporates international standards as well as specific KYC and AML regulations applicable to the relevant jurisdictions.

1. What Are Money Laundering and Terrorism Financing?

Money Laundering is the process by which proceeds from criminal activities (such as corruption, drug trafficking, market manipulation, fraud, tax evasion, etc.) are concealed to disguise their illegal origin, allowing them to be used within the legitimate economy. Money laundering can be defined in several ways but generally involves disguising the source of illicit funds to make them appear lawful.

Terrorism Financing refers to the collection, solicitation, or provision of funds with the intent or knowledge that they may be used to support terrorist acts, terrorists, or terrorist organizations. Terrorists require financial resources regardless of whether they are part of large organizations controlling territories or smaller terrorist cells operating independently.

2. High-Risk Countries

Governmental and international agencies publish detailed information about countries whose financial or social systems pose a high risk for money laundering. Regulations require enhanced due diligence measures when dealing with individuals or funds originating from these countries. Additionally, these measures must address specific deficiencies or concerns identified by national or international authorities.

The use of WellWallet products/services is strictly prohibited for citizens and/or residents of the following countries (territories) and jurisdictions*:

Afghanistan, American Samoa, U.S. Virgin Islands, Guam, Iran, Yemen, Libya, State of Palestine, Puerto Rico, Somalia, Democratic People’s Republic of Korea, Northern Mariana Islands, United States, Syria, Russian Federation, Republic of Belarus, Republic of Sudan, Transnistria, temporarily occupied territories of Georgia, Turkish Republic of Northern Cyprus, Western Sahara, Federal Republic of Ambazonia, Kosovo, South Sudan, Canada, United Kingdom, Nicaragua, Trinidad and Tobago, Venezuela, Myanmar, as well as temporarily occupied territories of Ukraine.

*Please note that the above list of prohibited and high-risk jurisdictions is subject to continuous review and updates by WellWallet in compliance with applicable laws and regulations. Therefore, you are required to check the latest version available on our website.

3. Sanctions Policy

In line with our commitment to robust Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) practices, compliance with applicable laws and regulations, and adherence to international financial sanctions, WellWallet enforces a strict sanctions policy. This policy includes freezing transactions involving entities under sanctions or suspected of sanctions violations, as well as suspending or terminating the use of our services by Users engaged in such activities.

WellWallet takes all necessary measures to ensure that all Users entering into business relationships are screened against relevant notices issued by: United Nations (UN) Sanctions, United States Consolidated Sanctions, Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List, European Union Financial Sanctions, United Kingdom Financial Sanctions (HMT), Australian Sanctions, Swiss Sanctions List (SECO), Interpol Wanted List, Canadian Autonomous Sanctions Consolidated List, Office of the Superintendent of Financial Institutions (Canada), U.S. Bureau of Industry and Security, U.S. Department of State AECA Debarred List, U.S. Department of State Nonproliferation Sanctions, Other relevant lists and notices.

This policy ensures that WellWallet remains in full compliance with global sanctions regimes and maintains the integrity of its operations.

4. Know Your Customer (KYC)

When establishing business relationships, WellWallet prioritizes understanding the intended nature of a User’s activities to determine standard operating patterns. As the relationship evolves, all routine transactions conducted by the User are assessed against their declared activities. Any deviations or unexplained actions are closely examined to identify potential signs of money laundering or terrorism financing.

At the start of the relationship, personal information is collected, including citizenship, date of birth, and residential address. This data is crucial for assessing the risk of financial crimes, including Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) measures. In cases involving high-risk transactions, additional verification of the information provided by the User may be required.

Currently, you cannot use WellWallet’s services without completing the Know Your Customer (“KYC”) procedure. All Users must be identified and verified. Failure to provide the required information and documents, submitting false or incomplete information, or failing to comply with other requests will result in our Services being unavailable to you.

However, under Article 820 of Costa Rica Law No. 820 (“Law on Narcotic Drugs, Psychotropic Substances, Drugs for Unauthorized Use, Related Activities, Money Laundering, and Terrorism”), regarding the prevention of money laundering and terrorism financing, we reserve the right to waive the KYC procedure for Users whose deposit and/or withdrawal amounts are equal to or less than 10,000 USD (or its equivalent in any official or virtual currency). This condition may be applied at our discretion.

Any changes to the KYC procedure will be promptly incorporated into this Policy and communicated to both new and existing Users.