AML/KYC Policy

Introduction
Like.biz Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Like.biz being involved in any kind of illegal activity.
Both international and local regulations require Like.biz to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

OFAC Sanctions:
Like.biz will NOT deal or provide any services to any of OFAC (Office of Foreign Assets Control) sanctions countries in accordance with the law of United Arab Emirates.

AML/KYC Policy covers the following matters:
1. Verification procedures.
2. Sanctions and PEP lists screening.
3. Monitoring Transactions.
4. Risk Assessment.

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

1.1. Identity verification
Like.biz’s identity verification procedure requires the User to provide Like.biz with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Like.biz reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
Like.biz 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 Like.biz reserves the right to investigate certain Users who have been determined to be risky or suspicious.
Like.biz 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, Like.biz reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly in accordance with the Like.biz’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Like.biz is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

1.2. Card verification
The Users who are intended to use payment cards in connection with the Like.biz’s Services have to pass card verification in accordance with instructions available on the Like.biz’s Site.

2. Sanctions and PEP lists screening.
Like.biz screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
- on the onboarding stage when the user is submitting the application;
- on each anti-fraud and AML alerts (manually);
- monthly by running automatically with a script to re-check all DB of customers.

For the screening process performing Like.biz uses Crystal Blockchain data integrated into its proprietary software.

3. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Like.biz relies on data analysis as a risk-assessment and suspicion detection tool. Like.biz performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
1) Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
2) Case and document management.
With regard to the AML/KYC Policy, Like.biz will monitor all transactions and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when Like.biz has reasonably suspicion that such User engaged in illegal activity.

The above list is not exhaustive and Like.biz will monitor Users’ 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. Risk Assessment
Like.biz, 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, Like.biz 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.