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KYC guidelines

 

We at Multilogin follow the law and are law-abiding entrepreneurs and pioneers of the industry, therefore a know-your-customer (“KYC”) verification procedure with our customer support with the purpose of meeting Anti-Money Laundering rules (“AML rules”) is applied to persons wanting to subscribe to our Services.

 

The KYB verification procedure is similar to opening a bank account at a bank and meets the requirements arising from Estonian and European Union (EU) laws. Using the Service is considered an Information society service by the Information Society Services Act of the Republic of Estonia.

 

The purpose of the AML rules are to help detect and report suspicious activity including the offenses to money laundering and terrorist financing, such as fraud, market manipulation, averting the usage of stolen credit cards and PayPal accounts to access our Services. If, as a result of the AML rules and KYC verification procedure, the subscription payment is considered high risk, we may cancel the order at our own discretion as we do not welcome shady customers with the intent of money laundering, potential fraud or any kind of unlawful or malicious intentions.

 

All new waiting list applications, as well as product orders, are subject to the following of AML rules and KYC verification procedure that is a mandatory process of identifying customers and having knowledge of their background. Therefore we are required to ask from you to prove your authenticity by providing a Proof of Identity and in some cases other relevant documents such as Proof of Address. This is also to make sure that you are truly the owner of a credit card or a PayPal account that you intended to pay with for the Service.

 

If a payment is considered high risk we may cancel the order at own discretion.

 

We retain all rights to refuse service to any persons who do not agree to the AML rules and KYC verification procedure.

 

We reserve the right to check whether any financial sanctions limitations exist to persons wishing to subscribe to the Service. For this a “financial sanctions information search” is done. Please see our Privacy Policy for details about how we deal with International, European Union and National Sanctions.

 

We have to report if a person wishing to subscribe to the Service is listed and/ or an act or activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or what constitutes money laundering or terrorist financing or related offenses is detected.

 

We retain all rights to refuse service to any persons if circumstances indicate or lead to suspect that money laundering, terrorist financing or attempted money laundering is at hand. We also retain all rights to refuse service to any persons under formal financial sanction. We are obliged notify to the Financial Intelligence Unit (FIU) if  such persons attempt to subscribe to the Service.

 

We are required to pay close attention if a person wishing to subscribe to the Service is domiciled or the payee's payment service provider is established in a third country or territory where adequate anti-money laundering and anti-terrorist financing measures have not been taken or if that country or territory does not cooperate internationally or has a low rate of anti-money laundering and anti-terrorist financing territory. According to the FIU, the following countries have equivalent requirements to the European Union for the prevention of money laundering and terrorist financing: Argentina, Australia, Brazil, Canada, Hong Kong, Japan, Mexico, New Zealand, Singapore, Switzerland, South Africa, and the United States.

 

We regret that these measures are necessary, but they are designed to protect owners of credit cards and PayPal accounts, as well as all other persons involved in the global economy.

 

To go through the AML rules and KYC verification procedure we provide Options for credit card payments or PayPal (you can choose one of the alternatives):

 

1. Send us a copy of your picture ID and copies of documents

 

For a natural person it is required:

 

Scan the image or take a picture in .pdf/ .jpg/ .jpeg format of your ID.

 

The ID can be, but is not limited to:

  • a valid digital identity card (ID-card) issued by your state authorities;

  • picture page of passport or diplomatic passport;

  • residence permit card;

  • alien's passport;

  • seaman's service book;

  • seaman's certificate;

  • temporary travel document;

  • refugee's travel document,

  • return certificate-permit;

  • a valid travel document (passport) issued abroad;

  • a valid driving license.

 

Whatever ID you have, it is important that the document contains all the required information:

 

  • the name and number of the document;

  • the date of issue;

  • the name of the issuing authority;

  • your full name;

  • photograph or facial image;

  • signature or signature image;

  • date of birth or personal identification code.

 

We only accept IDs from which the above listed required information is clearly visible.

If necessary, scan or take a picture of both sides of the ID, if the required information is not visible on one side.

 

The file of your ID will be stored securely with your account information at our records to meet  AML rules and KYC verification procedure with the following personal data that must be registered for identification purposes:

 

  • your full name;

  • personal identification code (in the absence of a personal identification code, date of birth and place of birth);

  • the name and number of the document used for identification and verification, the date of issue and the name of the issuing authority;

  • your postal address (we may additionally require a copy of an utility bill to your name corresponding to the address you give);

  • phone;

  • e-mail;

  • your profession or trade activity.

 

It is prohibited to establish a business relationship if the customer, despite a request to that effect, fails to provide the necessary documents or information to enable the service provider to fulfill the duty of care imposed by law.

 

For a legal person it is required:

 

  • the name (and business name, if applicable) of the legal person;

  • the legal address and place of incorporation;

  • registry code or number;

  • if applicable VAT/ TIN number;

  • copy of your picture ID in a way that the date of issue of the ID and the name of the issuing authority of the ID of the representative of the legal person are clearly visible;

  • the name(s) of the members of board or the names of member of another body replacing the board and their powers to represent the legal person;

  • the field of activity of the legal person;

  • means of communication (phone, e-mail);

  • details of the beneficial owners* of the legal person.

 

All of the above information may be submitted by presenting an extract from the Business Register where the information is shown and understandable (in Estonian, English, Russian or 中文 – Zhōngwén).

 

  • a power of attorney to represent the legal person if the representative of the legal person is not a member of the board;

  • only in the Republic of Estonia: if the legal person is registered is in Estonia and a branch of a foreign company registered in Estonia -an extract from the e-Business Register card or a copy of the relevant branch registration certificate or equivalent issued by a competent authority or body, not earlier than six months before the date of submission.

 

Other notes for legal persons and persons of national background:

If a representative of a legal person subscribing to our Service has or has had a national background in another EEA State or a national background in a third country (head of state, minister, high official etc), the representative or the national person him or herself must provide information whether the person performs or has performed essential functions of public authority or is a close associate or family member of the person performing important functions of public authority. A person with a national background shall not be deemed to be a person who, at the date of the transaction, has not or whose family members and close associates have not performed significant functions of public authority for at least one year.

 

*the beneficial owner is a natural person who, by exercising his or her influence, exercises control over a transaction, acts for other person’s interest or benefit or at who’s expense the transaction or act is performed. A beneficial owner is also a natural person who ultimately owns shares in the company or exercises ultimate control over the management of the company in at least one of the following ways:

  • holding more than 25 per cent of the shares, stocks or voting rights through direct or indirect ownership or control, including in the form of bearer shares;

  • otherwise controlling the management of the legal person.

If no natural person has control through a shareholding, the details of those persons who have other control over the legal person or entity (if any) are recorded. If this cannot be established, the details of the persons acting in a higher-level management body are recorded (the persons controlling the activities of the legal person).

 

The identification of beneficial owners by virtue of the holding of shares, stocks or voting rights or the exercise of ultimate control shall not apply only to legal persons whose securities are admitted to trading on a regulated market.

 

2. Pass a video interview with our customer support representative

 

Our customer support representative can schedule a video interview at a convenient time for you. For this contact support@multilogin.com for details.

 

We reserve the right to record the video interview and/ or take screenshots as required to store the information, e.g. the image of your picture ID. Such files of the video interview and/ or screenshots will be stored securely with your account information at our records to meet AML rules and KYC verification procedure and answering to the questions of our customer support representative in the video interview replaces the need to send us any copies of documents. The requirements for the video interview are pretty much the same as with the first option of sending us a copy of your picture ID and copies of documents, but can be done more quickly and conveniently and nothing needs to be sent to us.

 

Please be certain your contact information is correct as Applications or orders with an invalid phone and e-mail will certainly be canceled.