This KYC/AML Policy is current as of April 15, 2018. EpigenCare reserves the right to change or update this policy.
Purpose. All Purchasers of EPIC tokens will be required to undergo a Know-Your-Customer (“KYC”) verification process. This process is designed to prevent and mitigate risks of EpigenCare being inadvertently involved in any illegal activities. Regulations require EpigenCare to implement internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery.
Identify Verification. To establish the identity of the Purchaser prior to distributing EPIC, EpigenCare will require the Purchaser to submit identification to prove one’s identity and country of residence. This may include but is not limited to government identification, driver’s license, or a passport. For such purposes, EpigenCare reserves the right to collect additional and sufficient information or documentation to establish the Purchaser’s identity and confirm the authenticity of documents and information provided by the Purchaser. Only legal methods to verify identity will be used. EpigenCare reserves the right to reject or investigate Purchasers who have been determined to be risky or suspicious. Purchaser identity and documents will be collected, stored, and secured in accordance with EpigenCare’s Privacy Policy and related regulations.
Compliance Officer. The Compliance Officer is the person, duly authorized by EpigenCare, whose duty is to ensure the effective implementation and enforcement of this KYC/AML policy. It is the Compliance Officer’s responsibility to supervise all aspects of EpigenCare’s anti-money laundering and counter-terrorist financing, including but not limited to: (a) Collecting Users’ identification information; (b) establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations; (c) monitoring transactions and investigating any significant deviations from normal activity; (d) implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; (e) updating risk assessment regularly; and (f) providing law enforcement with information as required under the applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement involved in prevention of money laundering, terrorist financing, and other related illegal activity.
Anti-Money Laundering Check. EpigenCare (and/or its delegate) may request such evidence as is necessary to verify the identity and source of funds of a prospective Purchaser and, if applicable, to confirm the AML status of any redeeming EPIC token holder. EpigenCare shall not deliver any EPIC tokens until all information required for verification purposes has been provided. The identity of the Purchaser will be processed through MemberCheck’s Anti-Money Laundering and Counter Terrorism Financing database and sanction lists. Participants who fail this check will be refunded their contributed amount, minus transaction fees and a nominal administrative processing fee, and will not receive any EPIC.
If, as a result of any information or other matter which comes to his attention, any persons residing in the United States that know or suspect or have reasonable grounds for knowing or suspecting that another person is engaged in criminal conduct or is involved with terrorism or terrorist property, and the information for that knowledge or suspicion came to their attention in the course of business in the regulated sector, or other trade, profession, business or employment, will be required to report such knowledge or suspicion to: (i) the United States Securities & Exchange Commission; or (ii) law enforcement authorities with jurisdiction to enforce laws regarding terrorism or terrorist financing and property. Such a report shall not be treated as a breach of confidence or of any restriction upon the disclosure of information imposed by any enactment or otherwise.
EpigenCare prohibits acceptance of funds by any persons or entities that are acting, directly or indirectly: (i) in contravention of any U.S. or international laws and regulations, including anti-money laundering regulations or conventions; (ii) on behalf of terrorists or terrorist organizations, including those persons or entities that are included on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Treasury Department’s Office of Foreign Assets Control [1] (“OFAC”), as such list may be amended from time to time; (iii) for a senior foreign political [2] figure, any member of a senior foreign political figure’s immediate family or any close associate of a senior foreign political, unless EpigenCare, after being specifically notified in writing that the Purchaser is such a person, conducts further due diligence, and determines that such acquisition shall be permitted; or (iv) for a foreign shell bank [3] (such persons or entities in (i) – (iv) are collectively referred to as “Prohibited Persons”).
[1] The OFAC list may be accessed on the web at http://www.treas.gov/ofac.
[2] Senior foreign political figure means a senior official in the executive, legislative, administrative, military or judicial branches of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a foreign government-owned corporation. In addition, a senior foreign political figure includes any corporation, business or other entity that has been formed by, or for the benefit of, a senior foreign political figure. The immediate family of a senior foreign political figure typically includes the political figure’s parents, siblings, spouse, children and in-laws. A close associate of a senior foreign political figure is a person who is widely and publicly known internationally to maintain an unusually close relationship with the senior foreign political figure, and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the senior foreign political figure.
[3] Foreign shell bank means a foreign bank without a physical presence in any country, but does not include a regulated affiliate. A post office box or electronic address would not be considered a physical presence. A regulated affiliate means a foreign shell bank that: (1) is an affiliate of a depository institution, credit union, or foreign bank that maintains a physical presence in the United States or a foreign country, as applicable; and (2) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union, or foreign bank.