PRIVACY POLICY

Confidentiality and anti-money laundering policies


Finally, DOURADO.CASH has designated a Compliance Official who will have all the logistic, financial, and technological support to enforce this policy and will ensure the effective, efficient, and opportune functioning of SARLAFT:

DOURADO.CASH will make no exceptions in its dealings with Publicly Exposed Persons (PPE by its acronym in Spanish) and Politically Exposed Persons (PEP by its acronym in Spanish), who will undergo more exhaustive due diligence. Also, DOURADO.CASH will investigate the origin of the funds being traded for cryptocurrency on the platform as an integral part of the ML/FT risk management.

DOURADO.CASH has established protocols to know who its users and counterparties are through the collection, verification and registration of updated information.

‘Due diligence’ is the fundamental element for this policy’s development and for the procedures established to protect the interests, business, contracts, and operations of DOURADO.CASH with its users.

This policy is developed through the System for Managing the Risk of Money Laundering and Financing of Terrorism (SARLAFT by its acronym in Spanish) Manual, which establishes that DOURADO.CASH must identify and validate the identity of its users and other counterparties, know the final beneficiary and carry out monitoring of cryptocurrency transactions, to the purpose of identifying operations or activities which deviate from normal behavior.

DOURADO.CASH (from hereinafter referred to as DOURADO.CASH) has established a series of measures and procedures as a policy for managing the risk of Money Laundering and Financing of Terrorism, to prevent the site from being used, directly or indirectly, to carry our illicit activities.


SARLAFT policy for managing the risk of money laundering and financing of terrorism


All persons who, in the context of any activities whether permanent or temporary, were to provide DOURADO.CASH with any kind of personal data or piece of personal information, has every right to know, update it or correct it.

Therefore and because of the foregoing, DOURADO.CASH acknowledges that it will manage every piece of personal information submitted with the utmost privacy, safety, transparency and respect during the term of any type of contractual relationship under the strictest legal requirements.


GAFI, FATF


The Group of Seven (G-7) Summit in 1989 established the Financial Action Task Force (GAFI/FATF). Since 2000, Brazil is an effective member of the Financial Action on Money Laundering Group (FAML/FATF), under the Organization for Cooperation and Economic Development (OECD). Brazil is also member to the Financial Action Task Force of Latin America (GAFILAT), which is an associated member of the FATF.

The FATF’s recommendations are the internationally endorsed global standards aiming to promote AML/CFT policies—both at national and international jurisdictions. The FATF regularly review its members’ legislation for compliance with the FATF standards.


CPLDFT


The Mercosur/SGT-4 'Commission for the Prevention of Money Laundering and Terrorist Financing' (CPLDFT) is coordinated by the central banks from the Mercosur’s member countries. The CPLDFT comprises national institutions responsible for AML/CTF framework in the banking, securities, insurance and others financial markets.


AML/CFT - Legislation and regulation


The Brazilian legislation combats money laundering and terrorism, endorsing the country's compliance with the best international practices and the FATF's Recommendations.


  • Law No.  9,613/1998 (the 'AML Law') created the Council for Financial Activities Control (Coaf) and stablished a comprehensive framework of anti-money laundering requirements for a wide range of financial institution. There are general requirements—introduced and enforced by the Brazilian supervisory authorities for customer identification, record keeping, suspicious transaction reporting, etc.

  • Law No. 10,701/2003 included financing of terrorism as a predicate offence for money laundering, enforcing the obligation for all financial institutions to report transactions suspected of being related to terrorism financing. 

  • Law No. 12,683/2012 criminalizes money laundering and any associated wrongdoings.

  • Law No. 13,260/2016 forbids terrorism and its financing.

  • Law No. 13,810/2019 enforces the immediate freezing of terrorist assets, in compliance of United Nations Security Council’s sanctions related to terrorist offenses.

  • Law No. 13,974/2020 ammended the AML Law introducing that Coaf functions as an independent authority with administrative link to the BCB, among other provisions.


Confidentiality and users’ personal information protection policies in DOURADO.CASH



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