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

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


Money laundering consists of hiding an illegal source of funds, converting 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).

Customers of the Store 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 Customer's identification information has changed or if their activity appears suspicious, the Store has the right to request updated documents from the Customer, 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:

  • Collecting identity information from Clients.
  • Updating and monitoring internal policies and procedures to create, review, submit, and store all necessary reports in accordance with existing laws and regulations.
  • Monitoring and tracking transactions to conduct an analysis of any significant deviations within the normal activities of Clients.
  • Creating a record management system to store and retrieve documents, files, forms, and records.
  • Regularly analyzing 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 that the Client provide additional information and documents.
  • Suspend or close the Client's account.

Retention of records and information reports


As part of our AML program, we maintain relevant documentation regarding the identity of the Client and the electronic transmission of funds they perform. The retention period for records is updated according to what is indicated in the current regulations.

The currently established period for retaining such records is ten years. The file must be completed in a way that is accessible to all employees who need to have access to the Client in question.

We will respond to written, motivated, and legally binding requests issued and justified by official authorities within the legal framework regarding accounts and transactions, searching our records to determine if we hold or have held any information, or have conducted any transaction 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 identification information of each of our clients before they carry out any transactions:

For individuals

  • Name and any other name used.
  • ID number, passport number, national identity card, residence card, driver's license number, or other identification number.
  • Residence information (address and/or utility company customer number, data, etc.).
  • Biometric verification.
  • Any additional information from the Client, if necessary to meet the requirements of the risk-based approach.

For companies or legal entities:

  • Company name.
  • Information about the principal place of business.
  • Contact information.
  • Incorporation data (registration number, date of incorporation, etc.).
  • Payment details and/or banking information.
  • Relevant information about the place of residence (address data or utility customer data).
  • Data of the individuals authorized to operate on behalf of the company and the details of the authorization.
  • Biometric verification of the manager and/or managers of the entity.
  • Any additional information from the Client, if necessary to meet the requirements of our risk-based approach.

We will apply relevant risk-based measures to verify the identity of each client and maintain the necessary records.

Risk assessment


In accordance with international requirements, The Store applies a risk-based approach to combat criminal activities. 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.