ANTI-MONEY LAUNDERING AND KNOW YOUR CUSTOMER POLICY
Geliyoo Bilişim Araştırma Geliştirme Sanayi ve Ticaret Limited Şirketi (“Xtremcoin”
and “Company”) pays great importance to the Account
security of the Users and does is best to provide best customer service.
Xtremcoin implements Zero Tolerance Policy within the framework of the Anti-Money
Laundering and Know Your Customer (“AML and KYC”) legislation
on money laundering, terrorism financing, identity theft and fraud activities for
its subsidiaries, enterprises, projects and their employees.
This Anti-Money Laundering and Know Your Customer Policy (“Policy”)
is prepared by adopting a risk based approach to prevent identity theft, fraud, money laundering and financing of terrorism
and to inform Users that all transactions and activities realized through Xtremcoin
Platform are carried out in accordance with AML and KYC legislation by evaluating
the transactions, products and services performed through the Xtemcoin Platform runned
by the Company.
- AML ve KYC Legislation: No. 5549 on the Prevention
of Money Laundering, Law No. 6415 on the Prevention of Financing of Terrorism,
Law No. 4208 on the Prevention of Money Laundering, Implementing Regulation
on Compliance with Obligations for Prevention of Laundering Proceeds of Crime
and Financing of Terrorism and Implementing Regulation on Measures for the
Prevention of Money Laundering and Financing of Terrorism and all other related
legal regulations and international conventions where Turkish Republic is
a party and all other international regulations.
- Account: The account opened by Xtremcoin Users
in order to benefit from all Xtremcoin services and products.
- Service: Purchase, sale, storage and clearing
services of Cryptocurrency with the Products and Services provided to the
User via the Xtremcoin Platform,
- Black Money: money, any negotiable instrument
substitute for money, goods, revenues earned by actions accepted as criminal
offenses pursuant to Turkish Criminal Law and all kinds of material benefits
and value gained by conversion of this money, documents and goods to each
- Anti- Money Laundering: All transactions aimed
at hiding the source and illegality of all kinds of material interests and
values to convert them to legal economic values,
- Cryptocurrency: Digital currencies such as bitcoin,
ethereum, litecoin, bitcoincash, ripple, xtremcoin, which allows Users to
make secure encrypted transactions and digital coin offering,
- User: Natural person, who is using Xtremcoin services
by opening an Account on Xtremcoin Website,
- Risk: The possibility of financial or reputation
damage caused by Xtremcoin Services and incurred by Xtremcoin, Users and
- Risky Country: Countries which do not have adequate
arrangements for the prevention of money laundering and financing terrorism,
do not cooperate adequately in the fight against these crimes or are considered
risky by authorized international organizations,
- Seller: Seller who sell Cryptocurrency through
- Zero Tolerance Policy: Xtremcoin will implement
AML and KYC legislation and Company policy very strictly (such as a User
will not be allowed to deposit money to his/her account without completing
KYC) and these rules will in no way be extended by Xtremcoin employees,
- Xtremcoin Website: https://www.xtremcoin.com/
website, its extensions, subdomains (such as https://apiv1.xtremcoin.com
and https://blog.geliyoo.com) and all other related content,
- Crime Revenue: Assets resulting from a crime,
- Offense of money laundering: To take the money
abroad, to hide the illegitimate source of the money or to shape an opinion
that the money is earned by legitimate means where the money was earned as
a result of an offense requiring 6 months or more imprisonment.
- Suspicious Transaction: Presence of information,
suspicion or suspicious situation that the assets subject to the transaction
obtained through illegal means or used for illegal purposes, in this context
for terrorist acts or for use by terrorists, terrorists acts, terrorist groups
or terror financers.
- The offense of terrorism financing: To fund or
collect a terrorist or terrorist organization willingly that it will be used
in whole or in part in the execution of prohibited acts in the scope of Article
3 of the Law on the Prevention of Financing of Terrorism;
- Xtremcoin Platform: Cryptocurrency trade platform
operated by Xtremcoin through Xtremcoin Website.
ANTI MONEY LAUNDERING (AML)
1. High Risk Group Operations
High risk group operations
are listed below:
- Actions that may or may not be considered as Suspicious Transactions under the
- Trade and clearing transactions with a single transaction amount or total transaction
amount equal to 100,000 TL or more than 100,000 TL,
- The User and its transactions which are doubtful about the accuracy, clarity
and adequacy of the credentials and registration documents,
- Transactions carried out from/to countries with risk,
- Complex transactions carried out to conceal the details of the transaction that
may create a risk,
- Unusual transactions where it is at Xtremcoin's sole discretion to define unusual.
2. Xtremcoin-Specific Measures
The measures taken by
Xtremcoin for the prevention of money laundering are as follows:
- Necessary personnel have been hired in order to implement this Policy,
- An Anti-Money Laundering Officer has been appointed to work diligently in this
- Regular trainings are organized within the Company,
- A detailed AML and KYC Policy to be implemented within the company has been prepared
and these policies are updated according to changing circumstances,
- Periodic and random risk management, analysis and audits are carried out,
- Xtremcoin management and its employees show ultimate attention not to accept
gifts, to help or donate to any political party, organization and association,
- Xtremcoin does not accept to cooperate with or open accounts for the people,
People, whose Account was suspended / frozen or closed, who are at the blacklists
of Xtremcoin and financial companies.
3. User-Specific Measures
In the context of the prevention
of money laundering, the user-specific measures taken are as follows:
- In order to complete the User Account opening process, the authentication process
- A security system is used to record user credentials, registration documents
- When a Suspicious Transaction is detected, User Accounts are frozen and/or closed
and all official authorities, including MASAK, and law enforcement officers are
notified regardless of the transaction amount.
- High risk group transactions are monitored and controlled in detail.
- All records are kept for 10 years due to legal obligations.
4. Anti-Money Laundering Officer
The Anti-Money Laundering
Officer is a Xtremcoin employee who is responsible for the implementation of this
Policy. The main duties of the Anti-Money Laundering Officer are:
People, who are carrying out the Suspicious Transaction and Anti-Money Laundering
Officer and other employees, who do not comply with the obligation to report Suspicious
Transaction, shall be responsible for all legal, administrative and penal sanctions.
- Preparing, storing and updating the policies, procedures, reports, contracts
and other relevant documents required to comply with the AML and KYC legislation,
- Management of the security system in which the users' credentials, registration
documents and logs are recorded,
- Notification of all official institutions, especially MASAK, and law enforcement
agencies, when suspicious transactions are detected by the technical teams,
- Risk management, analysis and audits carried out periodically and randomly,
- Periodically checking and reporting the analysis of transactions in high risk
- Checking whether Xtremcoin and the User-specific measures are taken by the relevant
units or not.
KNOW YOUR CUSTOMER (KYC)
Xtremcoin takes the following precautions to identify the user:
- Users and the ones acting on behalf of Users are identified and the User's credentials
are verified using valid and reliable documents and information
- Necessary measures are taken in order to determine who is the final beneficiary
and to verify his / her identity
- The type of purchase-sale relationship on the user's Xtremcoin Platform and the
information about the purposes for opening the account is obtained.
- The User and the transactions and trading relationships of the User on the Xtremcoin Platform
are monitored and these transactions are compared with the User's profile.
- The Risk profile is drawn up for money laundering and financing of terrorism
by taking into account the occupation, financial situation, business history,
Account, transactions, country of residence and other relevant indicators.
2. Information and Documents
- Information and the documents requested to open an Account from the User are
the first and last name of the User, TC. ID or passport information, address
(via an invoice), mobile phone number, e-mail address and IBAN.
- Xtremcoin will not establish a service relationship with the User who wants to
open a User Account with a nickname or alias or who refuse to provide the necessary
information and documentation.
- Xtremcoin reserves the right to request updated documents and information for
the User who has authenticated before and may suspend/freeze or close User's
Accounts that do not meet this requirement.
3. Enhanced Due Diligence
- In cases where information is requested by official institutions, when a Suspicious
Transaction is detected or when necessary (at the discretion of Xtremcoin), an
Enhanced Due Diligence is performed regarding Users and transactions.
- In this respect, Xtremcoin may, in a limited and measured manner, request additional
verbal or commercial information and documents in writing or via telephone, in
connection with the purposes set out in this Policy.
- Xtremcoin may suspend/freeze or close the User's Account, which refuses to provide
the requested information and documentation under Enhance Due Diligence and /
or the User Account found to have opened an Account with alias or nick names under
- In cases where it is deemed necessary to conduct an Enhanced Due Diligence on
the persons performing the operations in the High Risk Group defined in this
Policy, the relevant Anti-Money Laundering Officer and the relevant senior executives
of the Company will be informed about the issue.
MEASURES TAKEN UNDER THIS POLICY
1. Authentication for Logging In to the Account
The user will log in to the account through Google Authenticator 2-Step Verification.
2. Security Question>
When the User changes his/her password, changes his/her information and documents
and requests for Cryptocurrency purchase/sale, the security question (determined
when creating the account) is directed to the User. If the User is unable to answer
the security question, the Xtremcoin Platform system will not allow the corresponding
transaction to take place.
Other Documents related to AML&KYC Policy:
Internet Data Security Policy