This policy is the AML/KYC Policy of Coinerz Kft. (FullCoin or “us” or “we”) which was compiled according to the Hungarian Act of 2017. LIII.
Any questions relating to this policy should be directed to Coinerz Kft., H-2330 Dunaharaszti, Jendrassik György str. 6.
The purpose of this AML/KYC is to ensure not only that FullCoin are compliant with all the current legislation and requirements, but also to show that they take any form of illegitimate use of their services seriously.
Money laundering is where proceeds of crime are disguised so to give the appearance of a legitimate income. FullCoin will not tolerate any client abusing their services for such matters.
If FullCoin suspect any client is abusing their services for the purposes of money laundering, FullCoin reserve the right to suspend any transactions pending the outcome of an internal investigation. FullCoin reserve the right to report any suspicious activities to the police or relevant authorities without the client's knowledge.
In accordance with the current industry best practice guidelines, FullCoin have:
Appointed a Money Laundering Reporting Officer
Established a risk based approach towards assessing and managing the money laundering risks to the business
Established and maintain risk based customer due diligence and obtain identification and proof of address in accordance with KYC (know your customer) which includes enhanced due diligence checks for customers which may present a higher risk, this will be determined at the sole discretion of FullCoin.
Established and maintain risk based systems and procedures to monitor ongoing client activity.
Have procedure for flagging and reporting suspicious activity.
Any client is subject to having their transaction frozen should FullCoin be suspicious of fraudulent activity or any activity, which may be related to money laundering.
As part of our AML/KYC policy, we ensure that any client agreeing to use our services, is also agreeing - if it is requested by FullCoin - to provide us with identification documentation, including but not limited to the high resolution color scan of all sides of the following Personal Identity Documents and/or Proof of Address Documents.
Data that can be collected (according to the levels in the table below):
Mobile telephone number
Bank account number
Address (Country, Count, City, Address, Postal Code)
Place and date of birth
Accepted Personal Identity Documents:
Current valid full EU or non EU Passport
Current valid National ID card
Current valid Driving License
Accepted Proof of Address Documents:
Utility Bill (received via post, stated for the User’s name and address, not older than 3 months) — Gas, Electricity, Water, Telephone
Bank Statement (received via post, not older than 3 months)
In order to have adequate due diligence checks in place FullCoin set up different levels for the verification process:
active e-mail address, active mobile number, first and last name, bank account number
up till 800
up till 1000
up till 700
Requirements of Level1 + high resolution photo of the photographic Personal ID Document issued by the state (passport, national ID, Driving licence), high resolution photo of a Proof of Address document, and a photo of you as you hold the photographic ID document mentioned above and also a paper with the text (FullCoin and the given date) written on it that was sent by us. Please make sure that your selfie photo is in color and the information on your document is clearly visible.
up till 10000
up till 12000
up till 9000
Requirements of Level2 + personal contact for higher level customer diligence.
We require the documents to be sent to us in high quality (300 DPI, 400kB-2mB) colour format and please be informed that we cannot process PDF format. If the documents have more than one side then we require all sides to be sent to us. We reserve the right to reject any documents, which do not comply with the above.
We reserve the right to require additional information at any time to verify the client's identification and any further information that may be required to satisfy the Money Laundering Regulations.
It is important to know that each of this data is a unique identifier, but they are stored at the same place in our system. If any of these data changes, but at least one is matching with a prior transaction identifier then the system automatically links the new one to the other group of data, therefore you do not have to go through on a complete verification again.
What is important to know that even though each transaction is unique, but if at least 1 identifier is matching then the amount of these transactions is counting cumulatively in respect of our AML/KYC Policy, meaning the linked transactions are rolling over according to the Hungarian Act LIII. of 2017 (6§ (2)).
If our User is a person or entity from a high-risk third country, we are obliged to run advanced verificational steps to meet all the legal regulations of Anti-Money Laundering. The up-to-date list of high-risk third countries can always be found in the Annex of Act EU/2016/1675.
Please note that at the moment we cannot process orders arriving from U.S., North-Korean and Chinese citizens/residents/taxpayers.