Know Your Client / Anti Money Laundering Policy

2.1. The Company or the person designated by the Company will collect all information and documents from each customer who has created a user account at 4dev.com (the “Platform”) to enable the customer to be identified under this Policy based on the following principles:
risk-based management to identify and verify the identity of each customer,
recording all information and documents of the customer,
providing customers with notice that the Company will seek identification information to verify customers’ identities,
comparing whether the customer is on relevant international and national lists of suspected terrorists and/or sanctioned persons.

2.2. High-risk countries and questionable origins of client information and/or documents. The Company will carry out enhanced due diligence if the customer meets one or several of the following criteria:
the legal person is incorporated in an offshore jurisdiction and/or the customer’s shareholder(s) is incorporated in an offshore jurisdiction,
an individual or legal person from a high-risk country or sanctioned territory (collectively, the “High Risk Countries”),
information and/or documents provided by a client during the customer’s due diligence are of questionable origin. In all such cases, the Company shall take all necessary and reasonable steps to enhance its customer due diligence requirements and procedures, which the Company will decide upon according to section 2.3. (g).
The Company does not offer or provide Services to any customer who, as it follows from the information collected, is a citizen or a resident (tax or otherwise) of a state where the Company has decided not to provide its Services, as may be decided from time to time, and to any person included in the Watchlists Databases.

2.3. The customer shall undergo the following risk-based Customer due diligence and KYC identification program which may be carried out by the Company itself or by the person designated (KYC/AML Service Provider) by the Company:
the customer creates a user account at the Platform;
the customer uploads to his/her account the information and documents required under section 2.4 (a) to (j);
the information and documents submitted by the customer will be transferred to the KYC/AML Service Provider to verify the customer’s identity according to section 2.4 (k)-(l);
the KYC/AML Service Provider will review and verify the provided information and documents;
the KYC/AML Service Provider will perform a search regarding the customer in the Government Sanctions Lists, Politically Exposed Persons Lists, Anti-Terrorism Watchlists, Anti-Money Laundering (AML) Watchlists, CIA Watchlists, Global Watchlist, Disqualified Directors, and similar watchlists (collectively the “Watchlists Databases”);
the KYC/AML Service Provider will verify the customer or decline the customer after the customer information review and the search in the Watchlists Databases;
if the customer meets any of the criteria under section 2.2, then the Company will perform enhanced due diligence based on a risk-based approach or refuse such customer in the provision of Services and refund to that customer any funds that have been previously advanced by such customer to the account from which they had originated, in the same type and manner (if applicable), and within a reasonable time, unless otherwise is provided in this Policy and/or required by applicable laws and regulations;
The Company will request additional information and/or documents for customers from high-risk countries or if there is information and/or documents submitted by the customer referring to a higher risk of money laundering, terrorist financing, and sanctions.

2.4. Once the customer creates a user account at the Platform, the following information and/or documents will be collected for all accounts, and for any person (individual or legal entity) that is creating a new user account and whose name is on the account prior to providing any Services to such person:
name;
date of birth (for an individual) and a date of registration (for a legal entity);
nationality / citizenship (or a country of registration for a legal entity);
residence and domicile;
gender;
email;
phone number;
address (including the country, state, city, and address line);
information regarding the proof of identity (passport, driving license, or national identity card that includes a picture of the holder) for an individual;
photograph of the front and back side of the identity document and a “selfie” for an individual or certificate of incorporation, memorandum and/or articles of association, beneficial owners’ information, and such legal entity directors’ identity documents/information as provided above in j) and k) for individuals, and proof of a business address for a legal entity;
proof of residential address: a utility bill less than three months old or a bank statement for an individual, or a registered address or other location for a legal entity.
The customer may be requested to provide any other reasonable information and/or documents needed to verify the customer’s identity. Such information and/or documents may be provided via separate message or through any other means used by the Company in accordance with its policies and terms of use valid at the time.

2.5. Based on the risk, which shall be determined on a case-by-case basis, and to the extent reasonable, using risk-based procedures to verify and document all information received by the Company in regards to a customer, the Company will ensure and make all necessary efforts to form a reasonable belief that the Company (a) knows the true identity of a customer and (b) the information and documents provided by a customer are accurate and true. The Company and KYC/AML Service Provider will analyze all the information and documents received and/or collected from a customer to verify whether such information and/or documents are sufficient to form a reasonable belief that the Company knows the true identity of a customer. Customer identity may be verified through documentary and/or non-documentary means. The Company may use any appropriate method of verification based on each case’s risks.

2.6. In the event the Company and/or KYC/AML Service Provider find suspicious information in the information and/or documents provided by a customer that indicates possible money laundering, terrorist financing activity, or any other suspicious activity, the Company will report the activity in accordance with applicable laws and regulations to the respective authority (if necessary).

2.7. When the Company cannot form a reasonable belief that it knows the true identity of a customer (or in regards to a legal entity – its directors, shareholders, beneficial owners and/or any related persons), the Company has the right to:
deactivate the customer’s user account on the Platform,
close the user account after multiple attempts to verify the customer’s identity have failed,
refund to that customer any funds that have been previously advanced by such customer to the account from which they had originated, in the same type and manner, and within a reasonable time, unless otherwise is provided in this Policy and/or required by applicable laws and regulations, and
determine whether it is necessary to notify the authorities.

2.8. If the potential or actual customer either refuses to provide any part of the information described above when requested by the Company or the Company reasonably believes and/or has found that the customer has intentionally provided false, wrong, and/or misleading information, then the Company has the right to deactivate the customer’s account and consider closing any existing account.

2.9. Any funds that have been previously deposited by such customer shall be refunded to that customer to the originated account in the same type and manner within a reasonable time, unless otherwise is provided in this Policy and/or required by the applicable laws and regulations.