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Verator UAB AML POLICY

Last Updated: Jun 5th, 2024

The Verator Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML/KYC Policy") is designed to prevent and mitigate the risk of verator.io being involved in illegal activities.

Both international and local regulations mandate Verator to establish effective internal procedures and mechanisms to deter activities such as money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Furthermore, Verator is obligated to take action upon detecting any suspicious activity among its customers.
This AML/KYC Policy applies to all Verator customers. By creating an account on our website and/or using our services, customers agree to adhere to this AML/KYC Policy and pledge to comply with its procedures.
Verification procedures
Customer due diligence (CDD) is an internationally recognized standard for preventing illegal activities. Verator follows this standard by implementing its own verification procedures, which are in accordance with anti-money laundering (AML) and Know Your Customer (KYC) frameworks.
  • Identity verification
Verator requires customers to provide reliable and independent source documents, data, or information (e.g., national ID, international passport, driver's license, bank statement, utility bill) for identity verification in accordance with the AML/KYC Policy. Verator reserves the right to collect this identification information from customers.
To verify the authenticity of the provided documents and information, Verator will use all legal methods available. Additionally, Verator reserves the right to investigate customers who are considered risky or suspicious.
Verator may conduct ongoing identity verification, especially if identification information changes or if a customer's activity appears suspicious or unusual. Verator also reserves the right to request updated documents from customers, even if they have previously passed identity verification.
Customer identification information will be collected, stored, shared, and protected in strict compliance with Verator’s Privacy Policy and related regulations.
By confirming the customer’s identity, Verator aims to mitigate potential legal liabilities in cases where its services are used for illicit activities.
  • Card verification
To use payment cards with Verator's services, customers must complete the card verification process as detailed on Verator's website.
Sanctions and PEP lists screening.
Verator has established procedures to screen customers against government-sanctioned lists and Politically Exposed Persons (PEP) lists. These procedures encompass the following:
  1. Screening during the onboarding process when the customer submits their application.
  2. Manual review by the Compliance Officer for each anti-fraud and AML alert.
  3. Monthly automated re-checks of all customer databases using a script.
Compliance Officer
The Compliance Officer is authorized to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.
Appointed by Verator, the Compliance Officer is responsible for ensuring the AML/KYC Policy is effectively implemented and enforced. Key responsibilities include:
  1. Collecting customer identification information.
  2. Developing and updating internal policies and procedures to ensure proper preparation, review, submission, and retention of all required reports and records in compliance with applicable laws and regulations.
  3. Monitoring transactions and investigating any significant anomalies from normal activity.
  4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms, and logs.
  5. Regularly updating risk assessments.
  6. Providing law enforcement with necessary information as required by applicable laws and regulations.
Transaction Monitoring

Verator employs transactional analysis and identity verification to thoroughly understand its customers. Utilizing data analysis, Verator assesses risks and detects suspicious activities. The company's compliance tasks include data capture, filtering, record-keeping, investigation management, and reporting. Key functionalities of the system include:
  1. Daily screening of customers against recognized "blacklists" such as OFAC: This process involves aggregating transfers based on multiple data points, placing customers on watchlists or denial lists, initiating investigations as necessary, sending internal communications, and completing statutory reports when applicable.
  2. Management of cases and documents: Ensuring efficient handling and organization.

Aligned with its AML/KYC Policy, Verator monitors all transactions and reserves the right to:
  1. Report suspicious transactions to law enforcement through the Compliance Officer.
  2. Request additional information and documents from customers in case of suspicious transactions.
  3. Suspend or terminate a customer's account if there is reasonable suspicion of illegal activity.

This list is not exhaustive, as the Compliance Officer continuously monitors customer transactions to determine whether they should be reported as suspicious or treated as legitimate.


Employee Training
Verator offers extensive training programs to ensure employees are proficient in AML and KYC regulations, policies, and procedures.
  1. Training Programs: We regularly hold training sessions to educate employees on AML and KYC regulations, policies, and procedures.
  2. Training Content: Our training includes modules on identifying suspicious activities, proper customer verification processes, and reporting protocols.
  3. Continuous Education: We provide ongoing education and updates to keep employees informed about changes in laws and industry practices.
  4. Training Records: We keep detailed records of all training sessions, including attendance and materials used.
Verator ensures thorough AML training for all new hires, covering AML procedures, detection of suspicious transactions, regulatory requirements, and reporting duties. Employees receive comprehensive briefings on the company's policies and procedures designed to prevent money laundering. To keep employees updated on the latest trends and practices, regular AML training sessions are conducted at least annually. Training records are meticulously archived to demonstrate compliance and support ongoing employee awareness and vigilance.

Periodic Review and Updates
Verator ensures that its AML and KYC policies are always up-to-date and compliant with current laws and regulations through regular reviews and updates.
  1. Policy Review: Conducting a comprehensive review of AML and KYC policies at least once a year.
  2. Regulatory Changes: Promptly updating policies in response to changes in relevant laws and regulations.
  3. Internal Audit: Performing regular internal audits to ensure compliance with AML and KYC policies.
  4. Feedback Mechanism: Implementing a system to receive and incorporate feedback from employees and stakeholders on the effectiveness of AML and KYC measures.


Record Keeping
Verator ensures the preservation of records for five years from the termination date of business relationships with customers:
  1. Document Copies: Retaining copies of documents and information gathered through   Customer Due Diligence (CDD) measures, including those obtained via electronic identification.
  2. Transaction Evidence: Keeping evidence of transactions and records, including original documents or their copies necessary for transaction identification.
  3. Analysis Results: Storing the results of ongoing analyses of executed transactions.
The retention period may be extended for an additional five years if mandated by law. The primary aim of record keeping is to maintain a detailed trail of evidence to assist the Compliance Officer and authorities in investigating money laundering allegations. This practice is crucial for supporting financial investigations and ensuring that illicit funds do not infiltrate the financial system. If such funds do enter, record keeping aids in their identification and seizure by authorities. Regardless of whether records are in paper or electronic format, they must be securely stored and easily retrievable within 24 hours when needed.

Risk Assessment
In line with international standards, Verator has implemented a risk-based approach to combat money laundering and terrorist financing. This strategy ensures that preventive and mitigating measures are proportional to the identified risks, allowing for efficient resource allocation. The core principle of this approach is to prioritize resources, directing the most attention to the highest risks.
Contact Information
If you have any questions or need more information about this AML/KYC Policy, please contact us at info@verator.io.
Help Center
Verator UAB, Reg.Nr. 306092631, Address at Lithuania Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius.

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