August 17, 2018, 3:10 PM UTC
IID Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of initialindex.com and Double Sirius Capital SPC and Double Sirius Managing Company Ltd. being involved in any kind of illegal activity.

I General introduction.

It is the policy of Double Sirius Capital Fund SPC and Initial index SP. (the “Company”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements of Cayman Islands Monetary Authority (“CIMA”).

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment.

Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable CIMA regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The “Company” operates so that it is compliant with ‘anti-money laundering’ (“AML”) and ‘know your customer’ (“KYC”) rules and regulations in the jurisdictions it operates in or sells products or services to and has developed this KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:

● The Company is performing an enterprise-wide risk assessment to determine the risk profile of the Company.

● The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company’s Board of Directors (the “Board”).

● The Company is implementing internal controls throughout its operations that are designed to reduce risks of money laundering, including designating a person responsible for AML compliance.

● The Company performing know your customer (“KYC”) procedures on all token sale purchasers.

II Purchaser Identification (Know Your Customer)

The Company has taken The Company collects identifying information on each purchaser in its token sale. The Company shall collect the following information about each purchaser: ● First name ● Last name ● Citizenship ● Date of birth ● For entities, Papyrus collects all of the above for a director of the entity.

III Contributor Eligibility the Company shall not accept purchasers (individuals or entities) who are not at least eighteen (18) years of age.

  • Any purchasers that purchase DAS SP tokens in violation of the T&C shall be invalid and such purchasers will have their purchase amount returned to them at their expense.

IV AML Screening

The Company shall screen each prospective purchaser in its token sale for matches in the following categories:

  • Global Sanctions List - Screening prospective purchasers against OFAC sanctions. ● PEPs - Screening prospective purchasers for identification as a "politically exposed person". A PEP is a term describing someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.

VI Verification procedures

    1.One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, DAS SP establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

Identity verification

    2.DAS SP’s identity verification procedure requires the User to provide DAS SP with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes DAS SP reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
    3.DAS SP will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and DAS SP reserves the right to investigate certain Users who have been determined to be risky or suspicious.
    4.DAS SP reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, DAS SP reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
    5.User’s identification information will be collected, stored, shared and protected strictly in accordance with the DAS SP’s Privacy Police and related regulations.
    6.Once the User’s identity has been verified, DAS SP is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

VII Compliance Officer

The Compliance Officer is the person, duly authorized by DAS SP, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of DAS SP’s anti-money laundering and counter-terrorist financing, including but not limited to:

    а. 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. f. Providing law enforcement with information as required under the applicable laws and regulations.

    b. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

VIII Risk Assessment

DAS SP, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, DAS SP is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.