Back

General Terms & Conditions for Lykke

Please find below the General Terms & Conditions for Lykke. For each platform the Terms and Conditions are composed of the General Terms of Use combined with the specific Trading Rules for the relevant platform.

LYKKE CORP UK - GLOBAL ANTI-MONEY LAUNDERING ("AML") PROGRAM

Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.

In response to the scale and effect of money laundering, the European Union has passed Directives designed to combat money laundering and terrorism. These Directives, together with regulations, rules and industry guidance, form the cornerstone of our AML/CTF obligations and outline the offenses and penalties for failing to comply.

Lykke Corp UK is currently under the temporary crypto asset regime of the FCA and therefore, fully complies with the AML/CTF obligations. Lykke has implemented systems and procedures that meet the standards set forth by the national and international AML regulations. The company’s AML / CTF policy and procedures are designed to prevent money laundering and to impede criminals to launder proceeds of crime.

GLOBAL ANTI-MONEY LAUNDERING (AML) POLICY:

Lykke’s AML Policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

  • Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
  • Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • Maintaining appropriate records for the minimum prescribed periods;
  • Providing training for and raising awareness among all relevant employees.

ONBOARDING / KYC POLICY:

KYC is done on every customer (proof of identity, selfie/liveness test, proof of address, screening system against sanctions lists, PEP and adverse media, etc.)

The onboarding process is designed to allow Lykke to gather information on potential customers and to detect any possible redflags. The customer must:

  • Provide identification documents, which are then verified in compliance with FCA and EU standards.
  • Provide a Selfie (the customer must take a photo).
  • Provide his/her proof of address which is verified manually by Lykke’s KYC team.
  • Answer a specific set of KYC questions (e.g. purpose of the business relationship, planned activity, source of funds, employment and income information, confirmation that the customer is the beneficial owner of the assets).

In addition, Lykke deploys a screening system against sanctions lists, PEP and adverse media. This ensures a global coverage of sanctions and watch-lists. Lykke leverages the system to review new clients, as well as to monitor the existing client base.

Lykke has a specific process in place for the onboarding of corporate customers. Corporate Customers are required to go through a special due diligence process (questionnaire and relevant documentation needs to be provided).

If the participant has any questions about the Privacy Policy or the collection and use of information by Lykke, it should contact the Data Protection Officer: dpo@lykke.com.