KYC Policy

Coinygram Ltd. [C 88670], a Maltese Registered Company with Office Address situated at: Coinygram Ltd., Phoenix Business Centre, Old Railway Track, 9022 Santa Venera, Malta, which owns and operates the ‘Coinygram’ VFA Exchange Platform in Malta,  hereinafter referred to as “Coinygram Ltd.” or “Coinygram” or “company”, which term shall refer to and include its owners, its subsidiaries and affiliated companies, directors, investors, employees, officers, representatives, affiliates, or other related parties.

In order to prevent misuse of the Coinygram Platform, Users are required to strictly comply with the terms contained herein, which forms part and parcel of the User Terms of Service. Terms not defined herein shall carry the same interpretation, as in the User Agreement and in the absence thereof to general usage and parlance.

“User” or “Client”: Persons availing of the Coinygram Services (as defined below), directly or indirectly, are referred to herein, as “Users”.

1. An opening of User Account

  1. A user may create a User Account by first downloading and installing the Coinygram App on their Android or iPhone smartphone by using the Google Play Store or iOS App Store, as applicable, subject to the terms contained herein.
  2. User shall comply with the procedures prescribed for opening the User Account, including providing a valid and existing email address and mobile number for completing the registration process and shall provide requisite know your customer (KYC) details and documents.
  3. Coinygram reserve the right to reject registration or validation of a User Account on any grounds as it deems suitable, at its sole discretion, with due regard to legal and regulatory framework concerning cryptocurrencies.

2. Know Your Customer (KYC) Compliance

In addition to the terms contained herein, Users shall be bound by the terms of Coinygram’s Anti-Money Laundering Policy (“AML Policy”), which is available at AML policy. By virtue of using any part of the Coinygram Services, and/or by virtue of accepting and entering into this Agreement, Users are deemed to have accepted and to have agreed to comply at all times with, the terms of the AML Policy. Only Users complying with the following Know Your Customers (“KYC”) procedures, as well as all terms and procedures contained in the AML Policy, would be allowed to avail of the Coinygram Services:

  1. Users shall provide the details, along with digitized copies of supporting documents for such details, simultaneously with the application for a User Account on the Coinygram Platform, failing which the User Account shall not be activated.
  2. User hereby consents to retention of the above details and documents by Coinygram for its own use, for as long as Coinygram required by law. Coinygram shall be entitled to retain user details and documents even for of those Users whose registration has been rejected by Coinygram.
  3. Coinygram shall take reasonable care and caution in the collection and retention of all information, data and documents provided by users. Coinygram shall comply with the terms of the Privacy Policy for collection and retention of User data, including personal data and information. The Privacy Policy may be periodically reviewed and revised, modified or updated.
  4. Acceptance of the terms herein shall be tantamount to acceptance of the Privacy Policy and the AML Policy, and the terms contained therein. Users are required to read, understand and affirm the AML Policy and the Privacy Policy before clicking the “accept and continue” button in the Coinygram platform.
  5. Coinygram may call upon User to furnish additional details and/or documents, either pursuant to governmental or regulatory requirements, or due to modifications in any of the terms of this Agreement, the Privacy Policy or the AML Policy. User hereby agrees and undertakes to comply with the same within the timelines prescribed.

3. Verification Process

  1. Coinygram shall, at its sole discretion activate the User Account upon verification of the details provided through the KYC process included in this Agreement and in the AML Policy. In the event of any factual inaccuracies or other problems with the details or documentation provided by a prospective User during this process, Coinygram shall be entitled to forthwith terminate the User Account without notice to the concerned User, and such User shall not be permitted to use the User Account or the Coinygram Services thereafter. Coinygram is entitled to terminate existing User Accounts for non–compliance with such requests for further details or information after due notice.
  2. Coinygram may, at its sole discretion, send to the User intimation of reasons for non-activation of a User Account. Coinygram is not under any obligation, however, to provide such notice.
  3. Only natural or legal persons may apply for a User Account and avail of any part of the Coinygram Services. Natural persons must possess a valid passport as an proof of identity and a national ID or driving license as proof of address. Legal persons must have valid formation and other documents as Coinygram may decide from time to time. Upon verification, any of the documents, information, or representations are found to be falsified, invalid or otherwise inaccurate, Coinygram shall forthwith terminate the relevant User Account without notice to the concerned User. Such termination might occur at the time of User Account opening or at a later point.
  4. Existing Users may be called upon to comply with the KYC and verification
  5. process contained in this Agreement and in the AML Policy. In the event of termination or deactivation of an existing User Account, Users shall be duly intimated by Coinygram, along with reasons for such deactivation and the procedures for redress (if any). Delay in termination of such User Accounts shall not amount to a waiver of the mandatory information and documentary requirements contained in this Agreement and in the AML Policy.
  6. In case of corporate, the antecedents of the company (name and registered office in particular) and of all promoters and directors will be traced. An assessment shall be made of the financial worthiness of the user by obtaining appropriate declarations as and when required.
  7. No users shall be accepted where it is not possible to ascertain the identity of the client, or the information provided is suspected to be non-genuine, or if there is perceived non-cooperation of the user in providing full and complete information. Coinygram shall not continue to do business with such a person and file a suspicious activity report. Coinygram shall consult the relevant authorities in determining what action it shall take when it suspects suspicious transactions being carried out.
  8. No transaction or account-based relationship is to be undertaken without following the user KYC and Due Diligence Process.
  9. Coinygram may, if so required under applicable Law, file know-your-customer records with the Central Registry of Securitisation Asset Reconstruction and Security Interest of Malta (“CERSAI”) within 3 days of onboarding a new User and may communicate a User’s KYC Identifier once it has been assigned by CERSAI for such User.

Know Your Customer Standards– The objective of the KYC guidelines is to prevent Coinygram Platform from being used, intentionally or unintentionally, by criminal elements for money laundering activities. KYC procedures enable Coinygram to know/ understand their customers and their financial dealings better which in turn help them manage their risks prudently. The KYC policy of the Coinygram incorporates the following elements:

  • Customer Acceptance Policy (CAP)
  • Customer Identification Procedures (CIP)

Customer Acceptance Policy (CAP)– The following Customer Acceptance Policy indicates the criteria for acceptance of customers

  • No account shall be opened in the anonymous or fictitious name(s)
  • No person can be Coinygram user below 18 years
  • All required KYC documents are mandatory
  • Account to be opened through Coinygram Platform only
  • A user can register/ open only one account with the same documents
  • Additional documents may be sought by Coinygram based on information security, etc.

Customer Identification Procedure (CIP)– Customer identification means identifying the person and verifying his/ her identity by using reliable, independent source of documents, data, information or by using third-party services. Coinygram needs to obtain sufficient information necessary to establish, to its satisfaction, the identity of each user. Subject to Coinygram’s risk analysis, the nature of information/ documents required would also depend on the type of customer.

4. List of KYC documents

Individual/Proprietor

Documents required

  • Valid Passport copy
  • National Id Card or Driving License

Corporate

Documents required

  • Certificate of incorporation and Memorandum & Articles of Association, or any other relevant founding documents.
  • Resolution of Board of Directors to open an account with Coinygram, and identification of those who have authority to operate the account
  • Copy of a company telephone landline bill or a recent company bank account statement addressed to your company name and office address.
  • A photo ID of all Board director
  • Id & Address proof of an Authorised person

Note: Apart from these above documents Coinygram reserves the right to call for additional documents for further verification based on Users volume and monitoring pattern.

5. Support

  1. If the User has any complaints, feedback or questions, the Company may be contacted via [email protected] and we will in our best efforts try to resolve the issue with expediency. Coinygram shall not provide any support services to walk-in users.

6. Modifications

  1. These terms may be periodically reviewed and revised. The revised terms will be uploaded on the Coinygram Platform and will reflect the modified date of the terms. The User is required to periodically visit the Coinygram website and review terms and any changes thereto.
  2. Continued use of the Coinygram Services constitutes the agreement of User to the terms contained herein and any amendments thereto.
  3. This agreement or the responsibilities or benefits arising therefrom cannot be assigned by User save and except with the prior written consent of Coinygram.