AML/KLC Policy

Madworld Anti-Money Laundering and Know Your Customer Policy (hereinafter – “AML and KYC Policy”)  is  designated to  prevent  and  mitigate  possible  risks  of  our operations being involved in any kind of illegal activity.

Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

This AML and KYC Policy applies to both natural and legal persons. Legal entities joining the Initial Coin Offering, which is defined as making a purchase in a specific method stated in the Clause 4 of this AML and KYC Policy will receive purchased tokens to their ERC-20 address after required AML and KYC procedures that include providing specific documents.

1. Verification procedures

   1.     Basis
      
      One of the international standards for the prevention of illegal activities is conducting Know Your Customer procedures (“KYC”). In order to access goods and services available on the Madworld’s platforms (“Platform”) or to be able to acquire non-fungible tokens (“NFTs”) and UMAD tokens, any User shall register on the Platform and  pass  the  “KYC”  identification process. According to the KYC process, we establish our own verification procedures within the framework of anti-money laundering standards and Know Your Customer.
   2.    Identity verification
      
      Our identity verification procedure requires the User to provide reliable independent sources of documents, data or information (e.g., ID card, international passport, bank statements, utility bills) to our satisfaction during the registration of an Account of a User. For AML and KYC Policy purposes, we hereby reserve the right to collect User information.
   3.    Anti-money laundering procedure
      
      Our anti-money laundering procedure requires the User to provide information about the source of the funds the User uses to purchase NFTs or UMAD tokens every time the User is requested to  provide  certain  information.  We  are  not  responsible  for  any  errors  or omissions in  the information provided by the User.
   4.    Authenticity verification
      
      We shall take steps to verify the authenticity of documents and information provided by the Users and use all legal methods to double-check identification information. We hereby reserve the right to investigate the actions of certain Users that we reasonably believe to be risky or suspicious and to take any appropriate action thereafter upon our sole discretion.
   5.    Right to report
      
      We may therefore be lawfully required to report our suspicions regarding any activity of the Users to local regulators, enforcement bodies and other compliance bodies or to furnish any information you had provided to us to such local regulators and relevant lawful authorities. Such actions have a goal of ensuring that the capital being used on the Platform has a legitimate origin and creates a safeguard in case of individuals or groups wanting to allocate their money from illegal activities or to use the Platform for any purposes in contravention of any AML regulations in any applicable jurisdiction on the Platform.
   6.    Continuous basis of information verification
      
      We hereby reserve the right to verify the User’s identity on a continuous basis, especially when the verification information has changed or the User’s activity has been deemed suspicious by us (regardless if they had already undergone previous identity verification). User verification information shall be collected, stored, transferred and protected strictly in accordance with our Privacy Policy and the relevant rules. Following the verification of User’s identity, we disclaim potential legal liability in situations where our Services are used for illegal activities.

   7.   Transaction proceed refusal
      
      We may refuse to proceed the transaction of transferring the purchased NFTs and/or UMAD UMAD tokens from or to the User and/or with any transaction in relation to goods and services from the Platform if:

      1. The User does not provide sufficient information requested by us to complete the relevant due diligence procedures on the User;
      2. The User has been previously identified as engaged in suspicious activity or is the subject of any UN sanctions, HM Treasury’s financial sanctions regime or is a person on the Specially Designated Nationals List, Denied Persons List, Unverified List, Entity List, or HM Treasury’s financial sanctions regime;
      3. The User is the citizen or resident of a country considered to be exposed to a high risk of money laundering or financing terrorism including but not limited to Cuba, Iran, Iraq, Libya,  Lebanon,  China,  Ethiopia,  Republic  of  Mali,  North  Korea,  Burma,  Belarus, Bosnia  and  Herzegovina,  Central  African  Republic,  Venezuela,  Yemen,  Zimbabwe, Somalia, Democratic Republic of Congo, Republic of Guinea, Guinea-Bissau, Nicaragua, the regions of Crimea, Donetsk and Luhansk in Ukraine, Russia, South Sudan, Sudan, Afghanistan or Syria or any other country as may from time to time be subject to United States embargo, UN sanctions, HM Treasury’s financial sanctions regime;
   8.    Payment cancellation.
      
      The User cannot cancel a request to purchase NFTs or UMADUMAD tokens. If the User is not able to provide sufficient information to prove his or her identity, we may cancel the User’s requested transaction with or without a refund upon our sole discretion.

2. Compliance Officer

   The following terms shall have, for the purposes of this Agreement, the following meaning:  

   1.    Definition
      
      The Compliance Officer is the person, duly authorized by us, whose duty is to ensure the effective implementation and enforcement of the AML and KYC Policy.

   2.   Duties
      
      It  is  the  Compliance  Officer’s  responsibility  to  supervise  all  aspects  of  our  anti-money laundering and counter-terrorist financing, including but not limited to:  

      1. Collecting the User’s identification information;
      2. 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;
      3. Monitoring  transactions  and  investigating  any  significant  deviations  from  normal activity;
      4. Implementing  a  record  management  system  for  appropriate  storage  and  retrieval  of documents, files, forms and logs;
      5. Updating risk assessment regularly;
      6. Providing law enforcement with information as required under the applicable laws and regulations.
   3.    Law enforcement
      
      The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
   4.    Contact with the clients and authorities
      
      The Compliance Officer is obliged to communicate effectively with the clients and authorities having any complaints or questions that are being addressed to him regarding tour AML and KYC Policy as also its implementation in order to ensure the transparency and credibility of the platform.

3. Monitoring transactions

   1.    Data analysis
      
      User  verification is carried out  not  only by checking their identity, but  also  by  analyzing transaction  models.  We  therefore  rely  on  data  analysis  as  a  tool  for  assessing  risk  and identifying suspicions. We carry out many regulatory compliance tasks, including, but  not limited to data collection, filtering and record keeping.
   2.   Suspicious transactions reporting
      
      With regard to the AML and KYC Policy, we will monitor all transactions, and we reserve the right to ensure that any transactions of suspicious nature in our opinion are reported to the proper law enforcement through the Compliance Officer and request the User to provide any additional  information  and  documents  in  case  of  suspicious  transactions.  The  Compliance Officer will monitor User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide

4. Payment methods

   1.    Payment cards usage control
      
      We may refuse to complete or block, cancel or reverse a transaction of the UMAD tokens purchase made with payment cards usage if the User is suspected of money laundering, terrorist financing,  fraud,  any  other  financial  crime,  or  any  other  illegal  action.  We  are  under  no obligation to disclose the details of its credit card risk management and security procedures to the User.
   2.   Transfer control
      
      We may refuse to complete or block, cancel or reverse a transaction if the User is suspected of money laundering, terrorist financing, carrying out or doing any actions that we suspect to involve fraud, any other financial crime, or any other illegal action in respect of any laws or regulations in any applicable jurisdiction.
   3.   Address analysis
      
      We may analyze the cryptocurrency addresses against common blacklists and known security discrepancies, to ensure that the funds do not come from or are involved with any illicit sources, and that there are no signs of money laundering (location, placements, layers, integration), either manually or by using a third-party service or through any other means.
   4.   Liability
      
      We have no control over, or liability for, the delivery, quality, safety and legality or any other aspect of any goods or services received or purchased through the Platform.

5. RISK ASSESSMENT
   
   We, in accordance with international requirements take a risk-based approach to combating money laundering and the financing of the terrorism. By applying a risk-based approach, we use our best endeavors to ensure that measures to prevent or mitigate money laundering and terrorist  financing  are  proportionate  with  the  risks  identified.  This  makes  it  possible  for resources to  be  allocated in the  most efficient  way.  The  principle is  to  allocate  resources corresponding to priorities so that the highest risks are given the closest attention.

6. AML and KYC Policy

   1.    Acceptance
      
      By registering and maintaining the registration of the User’s Account on the Platform, and/or purchasing the UMADUMAD tokens, the User accepts the terms of this AML and KYC Policy and  hereby  agrees  to  have  read,  understood  and  accepted  the  Terms  and  Privacy  Policy available  at our Platform. In addition, when using Our Services, the User may be subject to additional agreements applicable thereto. The User must stop using the services immediately and the Platform if they do not agree with the AML and KYC Policy, the Terms and Privacy Policy.
   2.   Privacy policy
      
      User’s  identification  information  will  be  collected,  stored,  shared  and  protected  strictly  in accordance with our Privacy Policy and any applicable regulations.