KYC / AML Policy

Introduction

Selfwork GmbH is committed to maintaining the highest standards of compliance with international anti-money laundering and know-your-customer regulations. This policy reflects our dedication to ethical business practices and our responsibility to protect our platform and users from financial crime.

1. Purpose

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy outlines the procedures and principles adopted by Selfwork GmbH to ensure compliance with international regulations and best practices for verifying the identity of users and mitigating risks related to money laundering, fraud, and other illicit activities. This policy is tailored to our operations as an online freelance marketplace platform and reflects our commitment to ethical business practices.

2. Scope

This policy applies to all users of Selfwork GmbH's online platform accessible on the website https://selfwork.com. It encompasses procedures for user identification, verification, and ongoing monitoring to ensure compliance with applicable laws and regulations.

3. Regulatory Compliance

This policy is informed by international standards, including:

• FATF (Financial Action Task Force) guidelines
• EU's AMLD (Anti-Money Laundering Directives)
• Swiss Anti-Money Laundering Act (AMLA)
• Other relevant international and local regulations

4. User Identification and Verification

4.1. Collection of Information

The following information is collected from each user:

• Full name
• Date of birth
• Nationality
• Residential address
• Government-issued identification document (e.g., passport, national ID, driver's license)
• For business accounts: company documents (extract from the registry, certificates of incorporation, proof of business address, shareholders agreement, authorized representative information)

4.2. Verification Process

User verification is conducted using Third-Party Verification Services, including but not limited to SumSub (https://sumsub.com/) and Stripe Identity. These providers ensure the authenticity of documents and match user information against reliable data sources.

4.3. Exclusions

Selfwork GmbH does not engage users or partners:

• Listed in any international sanctions databases;
• Identified as high-risk by Third-Party Verification Services' risk assessment tools;
• Flagged by internal checks performed by the AML Compliance Officer (AMLCO).

5. Risk-Based Approach

Selfwork GmbH employs a risk-based approach to KYC, which involves:

• Assigning risk ratings to users based on geographic location, activity patterns, transaction volumes, and other risk factors;
• Applying enhanced due diligence (EDD) for users flagged as medium or high risk;
• Implementing additional verification measures for high-value transactions.

6. Ongoing Monitoring

6.1. Transaction Monitoring

Selfwork GmbH actively monitors transactions on the Platform to identify and report suspicious activity, including unusual transaction patterns, attempts to circumvent payment systems, and other indicators of potential fraud or money laundering.

6.2. Periodic Reviews

User information is reviewed annually and updated to ensure continued compliance with KYC requirements. The AML Compliance Officer (AMLCO) is responsible for overseeing KYC requirements review.

7. Data Privacy and Security

All user data collected during the KYC process is handled in compliance with applicable data protection laws, including:

• GDPR (General Data Protection Regulation)
• Swiss Federal Act on Data Protection (FADP)

Selfwork GmbH ensures the secure storage and transmission of user data through encrypted systems.

8. Reporting Obligations

Selfwork GmbH is committed to filing Suspicious Activity Reports (SARs) with relevant authorities, including the Swiss Money Laundering Reporting Office (MROS), when required by applicable law.

9. Employee Training

All employees involved in KYC and AML processes undergo regular training to stay updated on compliance requirements and best practices.

It is mandatory that all user relations managers and relevant staff complete KYC/AML training before starting their job duties.

The AML Compliance Officer (AMLCO) is responsible for annual checks of employees' knowledge on AML/KYC policies and provides reports to the management.

10. Policy Review and Updates

This policy is reviewed annually or when significant regulatory changes occur. Updates are communicated to all relevant stakeholders and reflected in the version history of this document.