- IN GENERAL
Our company, Genesis Teknoloji ve Bilişim Hizmetleri A.Ş. (“Miracle Cash&More”) acts as a crypto asset service provider and uses its best efforts in order to fully fulfill its obligations in accordance with the applicable laws.
We are obliged to determine the identities of the people who will carry out the transactions carried out or mediated by our company (“KYC Processes”) and to take the necessary measures in this context.
This Anti Money Laundering Policy (the “Policy”) also contains explanations of our obligations under the applicable laws and the procedures implemented to ensure the safety of the activities carried out by Miracle. By accessing the https://miraclecash.com/ platform and/or using the services offered by Miracle, you (“Users”) agree the regulations stated in this Policy.
- FINANCIAL OFFENCES
- Laundering of the Proceeds of Crime
Laundering of the Proceeds of Crime is defined as the transfer of the value of assets obtained as a result of a crime abroad, the concealment of the fact that the amount was obtained from illegitimate sources or the making of various attempts to give the impression that such an amount has been obtained from a legitimate source.
- Financing of Terrorism
Financing of Terrorism is defined as the provision of funds to a terrorist or terrorist organization or the collection of funds for this purpose in order to be used in whole or in part in the realization of acts that are considered as terrorism crimes in accordance with the legislation to which it is subject.
III. POLICIES AND PROCEDURES
Miracle Cash&More implements measures against both its employees and Users in order to minimize the risks that may arise as a result of the trading transactions it mediates and to prevent and combat financial crimes.
Miracle Cash&More adopts internationally accepted and applied principles within the scope of the fight against financial crimes and constructs work times in this context. During the KYC procedures and in any case, all the necessary processes are operated in order to identify the Users, to make necessary notifications in case a suspicious transaction is detected, to check and store necessary information and documents before providing services and to share the these information and documents with the relevant authorities.
The main principles adopted by Miracle Cash&More within the scope of these processes are as follows.
- Miracle Cash&More acts as a crypto asset service provider that provides an environment for the trading of crypto assets.
- Transactions that are considered to be risky or suspicious are immediately reported to the relevant authorities and organizations.
- Effective methods are used to detect risky and suspicious transactions.
- Any action that is considered or likely to be considered as a financial crime is not allowed, on the contrary, Miracle Cash&More acts in full cooperation with the competent institutions and organizations in order to combat these actions.
- Necessary action plans have been established in order to prevent the completion of transactions that will be considered to be unlawful.
- KYC PROCEDURES
Miracle Cash&More fully implements the measures published by relevant authorities and organizations regarding the KYC procedures, especially the regulations and communiqués issued under the applicable laws. In this context, the main headings of the KYC procedures applied before the establishment of a relationship with the User are as follows:
- Obtaining the necessary information for identification from Users
- Determination of the purpose of the User to benefit from the services
- Determination of the User’s risk category
- Requesting additional information and documents from the User regarding the issues that cannot be clarified despite the completion of the steps mentioned above
In cases where identification cannot be completed or sufficient information about the purpose of the relationship cannot be obtained; the relationship will not be established with the User and the requested transaction will not be completed.
Even if a relationship is established with the User, the following KYC procedures shall be applied later on:
(i) Notification of suspicious transactions,
(ii) When it is considered that the information or documents shared by the User is not adequate or accurate, requesting additional information
(iii) When the transaction amount or the total amount of multiple transactions connected with each other is above $5,000, additional KYC procedures may be applied.
- RISKY AND SUSPICIOUS TRANSACTIONS
As stated above, during the services provided by Miracle Cash&More , all legal obligations are being fulfilled in order to prevent financial crimes. Various criteria have been established for the detection of financial crimes, and in accordance with these criteria, all procedures regarding the detection of the transactions that may constitute financial crimes and/or that must be reported in accordance with the applicable law are being applied.
The following transactions will be considered risky and suspicious by Miracle Cash&More:
– Transactions requested to be notified by authorized institutions and organizations
– Transactions for which a notification is required in accordance with the applicable law
– Transactions in which the accuracy of the information shared within the scope of KYC procedures is suspicious
– Transactions that are considered suspicious or risky as a result of the examination made by Miracle Cash&More
– Transactions that are suspected of committing financial crimes or fraud
– Transactions identified as being linked to any financial crime or fraud
– Transactions carried out contrary to the usual life
In this context, if necessary, risk analysis and transaction monitoring may be carried out for Users.
Some additional measures may be applied by Miracle Cash&More during the monitoring of the transactions of the Users, and if necessary, it may contact the relevant authorities and organizations without waiting for the completion of the aforementioned procedures. Users are obliged to provide the information and documents that may be requested by Miracle Cash&More within the scope of these procedures without delay, in full, within the period notified by Miracle Cash&More. In the event that such information and documents are not provided in full and in a timely manner and if submission of any information or documents will not eliminate the doubt as a result of the evaluation made, or if it is determined that the said suspicion is real until the information and documents are submitted, Miracle Cash&More, with its sole discretion, may immediately, partially or completely suspend the services provided to the User.
Miracle Cash&More will notify the relevant authorities and organizations about the transactions that are considered to be suspicious or risky and the criminal elements that it will detect within the scope of KYC procedures after completing the necessary examinations and will act in full cooperation with the aforementioned authorities and organizations.
Users who carry out suspicious transactions will be responsible for any damage or legal, administrative and financial liabilities.
VIII. INTERNAL CONTROL
Miracle Cash&More takes the necessary measures and periodically carries out audits in order for its personnel to be informed within the scope of KYC procedures and to carry out their duties in accordance with applicable laws. In this context, necessary educations are provided within the scope of the Policy and applicable laws and legal support is being received within the scope of the responsibilities.
Miracle Cash&More reserves the right to update this Policy upon updates to applicable laws, requests, instructions and guidelines shared by the relevant authorities and organizations, and/or as it may personally deem it.