• GENERAL

Our company, Fintech Investment Ltd. (“Miracle Cash&More”), operates as a cryptocurrency service provider and demonstrates maximum diligence to fulfill its obligations under the relevant legislation. We implement policies that have been meticulously prepared in order to comply with legal requirements.

In accordance with the Law on the Prevention of Money Laundering, Financing of Terrorism, and Proliferation of Weapons of Mass Destruction (“Law”), we are required to identify the identities of individuals conducting or intermediating transactions on behalf of our company (“KYC Processes”) and to take the necessary measures in this regard.

This Anti-Money Laundering Policy (“Policy”) includes explanations regarding our obligations under the Law and the procedures implemented to ensure the security of activities conducted by Miracle. Individuals accessing the platform at https://miraclecash.com/ and/or benefiting from the services provided by Miracle (“Users”) accept the regulations set forth in this Policy.

  • FINANCIAL CRIMES
  • Money Laundering

Money laundering is defined as the act of transferring the value of assets obtained from criminal activities abroad, concealing the illegitimate sources of funds, or taking various actions to create the impression that such funds were obtained from legitimate sources.

  • Financing of Terrorism

Financing of terrorism is defined as the provision of funds to a terrorist or a terrorist organization, either entirely or partially, for the purpose of carrying out acts classified as terrorism under the applicable legislation or for the collection of funds for such purposes. 

  • POLICY AND PROCEDURES

Miracle Cash&More implements measures for both employees and Users to minimize risks that may arise from the trading transactions it intermediates and to prevent and combat financial crimes.

Miracle Cash&More adopts internationally recognized and practiced principles in the fight against financial crimes and structures its operations accordingly. In the KYC Processes and prior to providing any services, all necessary procedures are thoroughly implemented, including the identification and verification of Users, the reporting of suspicious transactions, sharing necessary information and documents with relevant institutions and organizations, and maintaining those information and documents securely.

The main principles adopted by Miracle Cash&More within the mentioned processes are as follows.

  • Miracle Cash&More acts as a cryptocurrency service provider facilitating the trading of cryptocurrency assets.
  • There is no possibility of making payments in cryptocurrency for any goods and/or services provided by Miracle Cash&More.
  • Transactions deemed risky or suspicious are promptly reported to the relevant authorities and institutions.
  • Effective methods are used to detect risky and suspicious transactions.
  • Any action that is considered a financial crime or has the potential to be classified as such is not supported; on the contrary, full cooperation is maintained with the relevant authorities and institutions to combat such actions.
  • Necessary action plans have been developed to prevent the completion of transactions that may be deemed unlawful.
  • KYC PROCESSES

Miracle Cash&More implements the measures published by official institutions and organizations regarding KYC Processes in full compliance with the Law and the regulations and notices issued under the Law. In this context, the main headings of the KYC Processes applied before establishing a continuous business relationship with the User are as follows:

  • Collection of necessary information from Users for identity verification.
  • Determination of the purpose for which the User intends to use the services.
  • Identification of the User’s risk category.
  • Implementation of necessary measures for Users assessed as high risk.
  • Requesting additional information and documentation from the User regarding matters that cannot be clarified despite the completion of the steps mentioned above

In cases where identity verification cannot be performed or sufficient information about the purpose of the business relationship cannot be obtained, a business relationship cannot be established, and the requested transaction will not be carried out.

Even if a continuous business relationship is not established, the above-mentioned KYC Processes will be applied in the following situations: (i) when a suspicious transaction report is required, (ii) when there are doubts about the adequacy and accuracy of previously obtained customer identity information, or (iii) when the transaction amount or the total amount of multiple connected transactions is 75,000 TL (seventy-five thousand Turkish Liras) or more.

  • RISKY AND SUSPICIOUS TRANSACTIONS

As stated above, Miracle Cash&More takes utmost care to prevent financial crimes during the provision of services, and necessary processes have been established in this context. Evaluation and examination criteria have been created for the occurrence of financial crimes, and all actions regarding transactions that may constitute financial crimes, according to these criteria or as determined by the competent authorities, are taken without fail.

The following transactions will be considered risky and suspicious by Miracle Cash&More: 

  • Transactions for which notification is requested by competent authorities.
  • Transactions that require notification under the applicable legislation.
  • Transactions where there are doubts about the accuracy of the information shared under the KYC Processes.
  • Transactions assessed as suspicious or risky by Miracle Cash&More.
  • Transactions with any suspicion of constituting financial crime or fraud.
  • Transactions identified as having any connection to financial crimes or fraud.
  • Transactions conducted contrary to the normal course of life

In this context, if necessary, risk analysis can be conducted specifically for Users, and transaction monitoring can be carried out.

During the monitoring of Users’ transactions, Miracle Cash&More may take additional actions, and if necessary, contact the competent authorities without waiting for the completion of the process. Users are obliged to provide the information and documents that Miracle Cash&More may request within the specified time frame, without delay, completely and accurately. Failure to provide the information and documents fully and in a timely manner, or the assessment that any submitted information or document does not eliminate suspicion, or the determination that the suspicion is valid until the information and documents are submitted, may lead Miracle Cash&More to immediately suspend the services provided to the User, either partially or completely, and to terminate the contractual relationship with the User unilaterally.

 

  • NOTIFICATION

Miracle Cash&More will report suspicious or risky transactions, as well as any criminal elements identified within the KYC Processes, to the competent authorities after completing the necessary internal investigations and will act in full cooperation with those authorities.

  • RESPONSIBILITY

Users who carry out suspicious transactions will be personally responsible for the legal, administrative, and financial consequences related to such transactions.

  • INTERNAL CONTROL

Miracle Cash&More takes the necessary measures to ensure that its staff is informed about this Protocol and the applicable legislation and that they perform their duties in accordance with these regulations. Periodic audits are conducted for this purpose. Training on the Policy and legislation is provided, and legal support from professionals is sought on necessary matters. 

  • UPDATES

Miracle Cash&More reserves the right to update this Policy based on any changes in the applicable legislation, requests, directives, and guidelines shared by competent authorities, and/or when deemed necessary.