EXTRACT

  1. This document is an extract of the “Anti Money Laundering and Customer Identification Policy” (hereinafter as “AML” Policy) prepared and applied by MrCoin Ltd. and Shinrai Kft. (Hereinafter together as MrCoin).
  2. The complete Anti Money Laundering and Customer Identification Policy is available here.
  3. If you have any questions about this policy, please contact Selachii Law Office (96 Kensington High Street, London, W8 4SG).
  4. MrCoin, as a provider of exchange services between virtual payment instruments and regulatory money, is subject to DIRECTIVE (EU) 849/2015 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL and Act nr. LIII of 2017 on the prevention and deterrence of money laundering and financing of terrorism (hereinafter as Pmt.); it shall accordingly apply the provisions of the current legislation on the prevention and deterrence of money laundering and financing of terrorism.
  5. MrCoin Ltd. is a company incorporated under the laws of the United Kingdom, registered under number 08994240, with its registered office at Selachii LLP, 96 Kensington High Street, London, W8 4SG. Companies House, the business registration authority of the UK, regulates its activities.
  6. We carry out our activities in Hungary through the Commercial Representation of MrCoin Ltd. (1118 Budapest, Rétköz utca 5.), and we have concluded a cooperation agreement with Shinrai Kft. (1025 Budapest, Vérhalom utca 40.), also registered in Hungary, in order for this company to perform operational, brokerage and customer service tasks in connection with our service.
  7. A Pmt. applies to any entity established in Hungary or in another Member State of the European Union or in a third country and, through its permanent business unit established in Hungary, including a branch office, directly offers customers specific services in Hungary in the form of a permanent domestic presence, thus it shall also be applied to MrCoin's activities .
  8. The Policy shall be applied to all natural and legal persons using MrCoin's services, and to all MrCoin's representatives, employees, workers as well as agents, proxies and cooperating partners serving for the performance of its obligations defined in the present policy and with whom MrCoin comes into contact in connection with its business activities
  9. The Policy covers activities aimed at preventing and deterring money laundering and financing of terrorism, risk classification, screening and monitoring of clients, performance of tasks related to the reporting and registration of suspicious financial transactions, suspension of transactions, and implementation of financial and property restrictive measures (objects covered).
  10. MrCoin's purpose with this AML Policy is not only to comply with the legal provisions and requirements currently in force, but also to express that it will take very serious measures against any form of unlawful use of the services it provides.
  11. In money laundering, perpetrators want to make the proceeds of crime look like income of legal origin. MrCoin will not tolerate any of its customers trying to misuse the services provided by MrCoin for any such purpose.
  12. In the event that any of MrCoin's customers is suspected of abusing MrCoin's services for the purpose of money laundering, MrCoin reserves the right to suspend pending transactions until the completion of the internal investigation. MrCoin also reserves the right to report suspicious activity to the police or the competent authority without the knowledge and information of the client.
  13. In accordance with the relevant current best practice guidelines, MrCoin
    • has appointed a person responsible for official reports of money laundering,
    • developed a risk-based approach to assessing and managing business-related money laundering risks,
    • has established and operates risk-based customer due diligence processes and obtains the documents required to prove identity and address in accordance with the “know your customer” (KYC) principle. For higher risk customers, who are appointed as such in the sole discretion of MrCoin, enhanced customer due diligence will take place.
    • has established and operates risk-based systems and procedures in order to continuously monitor the activities of customers,
    • has processes in place to identify and report suspicious activity.
  14. The transaction of any customer may be suspended in the event that MrCoin suspects the customer of deceptive, fraudulent or any activity related to money laundering.
  15. As part of the AML Policy, we ensure that any customer who has agreed to use our service also agrees to provide us, upon request, with a high-resolution copy of each page of the documents required to prove their identity and / or address ( 300 DPI) in color, scanned or photocopied format, including but not limited to:
    • Documents proving identity:
      • A valid passport issued in an EU country or a valid passport issued outside the EU
      • Both sides of a valid identity card
      • Both sides of a valid driver's license
    • Documents proving the address:
      • Authority card proving the address (Address card)
      • Utility bill for the address - gas bill, electricity bill, landline phone bill
      • Bank statement containing the home address
  16. In order to comply with both the Pmt. and our own risk management regulations, customer due diligence is not limited to the establishment of a business relationship or the execution of a transaction order amounting to 12,000 EUR or more (the combined value of several interconnected transaction orders must also be taken into account).
    For orders placed on the Website, we use different levels of identification depending on the volume of transactions according to the table below. “crypto” means the various digital crypto currencies (e.g. Bitcoin, etc.) while “fiat” means the traditional currencies (e.g. HUF, EUR, USD, etc.):

    Level 1

    Daily limit Monthly limit
    crypto: from € 0 to € 160 crypto: from € 0 to € 800
    fiat: from € 0 to € 160 fiat: from € 0 to € 800
    fiat: from HUF 0 to HUF 60,000 fiat: from HUF 0 to HUF 300,000
    Identification requirement:
    1. contact mobile phone number
    2. contact e-mail address
    3. full name
    4. bank account number

    Level 2

    Daily limit Monthly limit
    crypto: up to € 800 crypto: up to € 4000
    fiat: up to € 800 fiat: up to € 4000
    fiat: up to HUF 300,000 fiat: up to HUF 1,500,000

    Identification requirement

    FOR PRIVATE PERSONS AND SOLE PROPRIETORS:
    Level 1 +
    high resolution photo of the followings:
    (1) a photograph of the customer's bank card showing the customer's full name with the bank card number and expiration date obscured
    (2) handwritten text on paper: "I [name] would like to exchange crypto money at MRCOIN.EU [signature]"
    Sample photos for private persons

    FOR COMPANIES AND PARTNERSHIPS:
    Level 1 +
    high resolution photo of the followings:
    (1) a photograph of the customer's bank card showing the customer's full name and the company name with the bank card number and expiration date obscured
    (2) handwritten text on paper: "I [name] would like to exchange crypto money on behalf of [company name] at MRCOIN.EU [signature]"
    Sample photos for companies

    Level 3

    Annual limit
    crypto: up to € 12,000
    fiat: up to € 12,000
    fiat: up to HUF 4,500,000

    FOR PRIVATE PERSONS AND SOLE PROPRIETORS:
    Level 2 +
    (1) a high-resolution scanned copy of each page of a customer's photo ID issued by the state
    (2) a high-resolution scanned copy of that page of the customer's proof of address document that contains the address

    FOR COMPANIES AND PARTNERSHIPS:
    (1) a high-resolution scanned copy of each page of the photo ID issued by the state for the representative of the company
    (2) a high-resolution scanned copy of that page of the company representative's proof of address document that contains the address
    (3) certificate of incorporation that is not older than 30 days or in case of newly established companies, the decision on incorporation (in .es3 format)
    (4) in the case of a foreign company: Decision in which the owners / members of the company provide that the representative of the company may exchange crypto currency at MrCoin for the benefit of the company
    (5) Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy)
    (6) Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy)

    Level 4

    Daily limit Monthly limit Annual limit
    crypto: from € 12,000 crypto: from € 12,000 crypto: from € 12,000
    fiat: from HUF 4,500,000 fiat: from HUF 4,500,000 fiat: from HUF 4,500,000

    FOR PRIVATE PERSONS:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. Showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy) if you are not acting on your own behalf
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy).

    FOR LEGAL ENTITIES:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. In case of natural persons acting on behalf and in the agency of customer, showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
    3. In case of a legal entity customer, besides the document required for proving and controlling the identity of the person acting on behalf or in the agency of such customer, it is also necessary to submit the document – that is not older than 30 days – proving the followings
      • the company has been registered by the court of registration or the company has submitted an application for registration;
      • in case of a sole proprietor, the commencement of sole proprietorship has been reported or the self-employed person has been registered;
      • in case of a domestic legal person, if its establishment requires official or judicial registration, a document certifying that registration has taken place;
      • in case of a foreign legal person or an organization without legal personality, proof that it has been registered or incorporated under the law of its own country;
      • furthermore, if the application for registration, official or court registration has not yet been submitted to the company court, authority or court, the articles of association (memorandum of association, charter) of the legal person or organization without legal personality must be submitted.
      In the latter case, the organization must certify by document within 30 days of the incorporation, official or court registration that the incorporation or registration has taken place.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy)
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy)

    For transactions initiated at ATM terminals, the following levels are used:

    Level 1

    Limit per transaction Daily limit
    crypto: from € 0 to € 25 crypto: from € 0 to € 160
    fiat: from € 0 to € 25 fiat: from € 0 to € 160
    fiat: from HUF 0 to HUF 10,000 fiat: from HUF 0 to HUF 60,000
    Identification requirement:
    No requirements

    Level 2

    Daily limit Monthly limit All time limit
    crypto: up to € 800 crypto: up to € 4000 crypto: up to € 12,000
    fiat: up to € 800 fiat: up to € 4000 fiat: up to € 12,000
    fiat: up to HUF 300,000 fiat: up to HUF 1,500,000 fiat: up to HUF 4,500,000
    Identification requirement:
    (1) contact mobile phone number

    Level 3

    Limit per transaction All time limit
    crypto: up to € 4000 crypto: up to € 12,000
    fiat: up to € 4000 fiat: up to € 12,000
    fiat: up to HUF 1,500,000 fiat: up to HUF 4,500,000
    Identification requirement:
    (1) contact mobile phone number (2) an ATM-made photographic copy of the front side of customer’s photo ID issued by the state (3) photo made by ATM of customer’s face (if the ATM supports this feature)

    Level 4

    All time limit
    crypto: from € 12,000
    fiat: from HUF 4,500,000

    FOR PRIVATE PERSONS:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. Showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy) if you are not acting on your own behalf
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy).

    FOR LEGAL ENTITIES:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. In case of natural persons acting on behalf and in the agency of customer, showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
    3. In case of a legal entity customer, besides the document required for proving and controlling the identity of the person acting on behalf or in the agency of such customer, it is also necessary to submit the document – that is not older than 30 days – proving the followings
      • the company has been registered by the court of registration or the company has submitted an application for registration;
      • in case of a sole proprietor, the commencement of sole proprietorship has been reported or the self-employed person has been registered;
      • in case of a domestic legal person, if its establishment requires official or judicial registration, a document certifying that registration has taken place;
      • in case of a foreign legal person or an organization without legal personality, proof that it has been registered or incorporated under the law of its own country;
      • furthermore, if the application for registration, official or court registration has not yet been submitted to the company court, authority or court, the articles of association (memorandum of association, charter) of the legal person or organization without legal personality must be submitted.
      In the latter case, the organization must certify by document within 30 days of the incorporation, official or court registration that the incorporation or registration has taken place.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy)
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy)

    Identification requirement:

    FOR PRIVATE PERSONS:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. Showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy) if you are not acting on your own behalf
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy).

    FOR LEGAL ENTITIES:

    1. The customer shall provide the Service Provider with all data required by the Pmt as mandatory on the form stated in Annex 1 and 2 to the Policy with the data content required there.
    2. In case of natural persons acting on behalf and in the agency of customer, showing in person or through audited electronic means of communication the following documents as well as providing a copy of such documents:
      • FOR HUNGARIAN CITIZENS an official ID card suitable for proving identity and an official address card proving the address, the latter in case the place of residence or stay is in Hungary;
      • FOR FOREIGN CITIZENS travel document or identity card of a natural person, provided that it enables the right to stay in Hungary, the document certifying the right to stay or the document granting the right to stay, the official certificate of residence in Hungary, if the place of residence or stay is in Hungary.
    3. In case of a legal entity customer, besides the document required for proving and controlling the identity of the person acting on behalf or in the agency of such customer, it is also necessary to submit the document – that is not older than 30 days – proving the followings
      • the company has been registered by the court of registration or the company has submitted an application for registration;
      • in case of a sole proprietor, the commencement of sole proprietorship has been reported or the self-employed person has been registered;
      • in case of a domestic legal person, if its establishment requires official or judicial registration, a document certifying that registration has taken place;
      • in case of a foreign legal person or an organization without legal personality, proof that it has been registered or incorporated under the law of its own country;
      • furthermore, if the application for registration, official or court registration has not yet been submitted to the company court, authority or court, the articles of association (memorandum of association, charter) of the legal person or organization without legal personality must be submitted.
      In the latter case, the organization must certify by document within 30 days of the incorporation, official or court registration that the incorporation or registration has taken place.
      • Declaration of Ultimate Beneficial Ownership (on the form in the annex to the Policy)
      • Declaration of Ultimate Beneficial Ownership by Politically exposed person (on the form in the annex to the Policy)

  17. Copies of documents sent to us must be high-quality, high-resolution color copies. If the document has multiple pages, each page must be sent. Otherwise, we reserve the right not to accept copies of documents submitted.
  18. We also reserve the right to request additional documents at any time to verify the identity of the customer or to request any additional information necessary to comply with anti money laundering regulations.