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AML Policy

Combination of measures used by NFTsky to stop the reintroduction of the proceeds of illegal activities. Official combination of the FATF recommendations and locally introduced laws.

Date of publication: June 22, 2022

Statement on Anti-Money Laundering and Illegal Foreign Exchange Transactions

PAYTOSAVE LIMITED Company No.: 227963 Address: Republic of Seychelles Suite 1, Second Floor, Sound & Vision House, Francis Rachel Str., (Hereinafter referred as “PaytoSave”) is committed to creating a compliant, safe and reliable digital asset trading environment for users, providing professional and reliable digital asset trading and asset management services to users around the world. The special statement is as follows:

Article 1.

Set of rules regarding the distribution and maintenance of information and records. Meant to protect customers or patients of a business.

Article 2.

Set of rules regarding the distribution and maintenance of information and records. Meant to protect customers or patients of a business.

In order to prevent involvement in illegal trading activities or illegal acts, users should pay attention to the following:

In order to prevent involvement in illegal trading activities or illegal acts, users should pay attention to the following:
In order to prevent involvement in illegal trading activities or illegal acts, users should pay attention to the following:
In order to prevent involvement in illegal trading activities or illegal acts, users should pay attention to the following:
Select and use safe and reliable third-party financial institutions for payment.

Article 3.

When official regulators and law enforcements present valid investigation request documents and request the platform to cooperate with the investigation or restrict the fund of a designated user, the platform will check the validity and authenticity of the judicial documents and comply given that the request is legitimate. The platform does not assume any responsibility for user privacy leakage, account inoperability, and other losses caused.

According to relevant laws and regulations and relevant regional and national standards, in the following situations, we may collect and use your personal information in accordance with the law without your consent:

(1) Directly related to national security and national defense security;

(2) Directly related to public safety, public health, and major public interests;

(3) Directly related to a criminal investigation, prosecution, trial, and execution of judgments;

(4) Out of the protection of your life or property and other important legal rights and interests, but it is difficult to obtain your own consent;

(5) The collected personal information is disclosed to the public by yourself;

(6) Collect personal information from legally publicly disclosed information, such as: legal news reports, government information disclosure and other channels;

(7) Necessary to sign and perform the contract according to your requirements;

(8) Necessary for maintaining the safe and stable operation of the provided services, for example: finding and handling service failures;

(9) Other circumstances stipulated by laws and regulations.

Article 4.

All users who use the services of this platform should know before the transaction: digital assets are not backed by any government or central bank, and the price of digital assets fluctuates greatly. Holding or using digital assets has a high risk. Before making trading decisions, you should review your financial situation diligently to determine whether it is suitable for you.

Article 5.

Anyone who logs in to the platform in any way or directly or indirectly uses the services of this website is deemed to voluntarily accept the constraints stated on this platform.

Article 6.

NFTsky has developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States and other countries where company conducts the business. This includes, but is not limited to:

Establishing robust internal policies, procedures and controls that combat any attempted use of NFTsky for illegal or illicit purposes and that are designed to ensure our customers basic protections under consumer protection laws;
Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
Filing Suspicious Activity Reports (“SARs”);
Filing Currency Transaction Reports (“CTRs”);
Maintaining comprehensive records of orders and other transfers;
Employing a Chief Compliance Officer (“CCO”) to act as our Bank Secrecy Act Officer and be responsible for the implementation and oversight of our BSA/AML Program;
Executing Know Your Customer (“KYC”) procedures on all customers;
Performing regular, independent audits of our BSA/AML Program;
Following record retention requirements; and
Implementing a formal and ongoing compliance training program for all new and existing employees.

Article 7.

Our BSA/AML Program has been reviewed and approved by our Board of Managers (the “Board”). Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. We are regulated by the New York State Department of Financial Services (“NYSDFS”) and our BSA/AML Program is subject to its review and approval.

Article 8.

We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.

Article 9.

All of our employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

Article 10.

Our CCO is responsible for developing and enforcing the policies and procedures of our BSA/AML Program. Our CCO is required to report any violations of our BSA/AML Program directly to our CEO and our Board. In addition, our CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.

Article 11.

Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

Article 12.

In order to open an account and use NFTsky, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use NFTsky.

Article 13.

Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:

Email address;
Mobile phone number;
Full legal name;
Social Security Number (“SSN”) or any comparable identification number issued by government;
Date of birth (“DOB”);
Proof of identity (e.g., driver’s license, passport or government-issued ID);
Home address (not a mailing address or P.O. Box); and
Additional information or documentation at the discretion of our Compliance Team.

Non-US customers are required to provide an additional proof of identity (e.g., driver’s license, passport, or government-issued ID). If you successfully meet and complete our CIP requirements and do not appear on the OFAC or any other government watchlist, then we will provide you with account opening agreements electronically.

Article 14.

Institutional customer — Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:

Institution legal name;
Employer Identification Number (“EIN”) or any comparable identification number issued by government;
Full legal name (of all account signatories and beneficial owners);
Email address (of all account signatories);
Mobile phone number (of all account signatories);
Address (principal place of business and/or other physical location);
Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
Contract information of owners, principals, and executive management (as applicable);
Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).

If your institution successfully meets and completes our CIP requirements and neither it nor any of its owners, principals, executive, or managers appear on OFAC or any other governmental watchlist, we will provide you with account opening agreements electronically.

Article 15.

We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on NFTsky. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity.

CCO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR. In addition, all currency transactions over a determined USD value are be reported to FinCEN via a CTR filing. Our CCO maintains records and supporting documentation of all SARs and CTRs that have been filed. All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency. The CCO is responsible for performing an audit of our BSA/AML Program at least annually, and presenting the results to our President, CEO and Board. Our CEO oversees the performance of an independent test of our BSA/AML Program at least annually. The CCO is not responsible for the independent test, and the CCO’s performance is a subject of the test. Results are sent directly to the Audit Committee of the Board and for review.