CL Singapore Pte. Ltd. (“CLS” or “Netleaders”) conducts its business operations worldwide and offers both individual and institutional customers access to the DasEcosystem through online purchase of the Gateway Licenses (“License”).
CLS does not run any virtual currency exchange platforms nor handle virtual wallets for its customers. However, each License holder may apply to use such services, which are provided by third parties within the Ecosystem.
CLS applies the Know Your Customer program (“KYC Program”) based on the highest international standards and regulations relating to customer due diligence in Singapore. The KYC Program makes up a part of the anti-money laundering procedures and measures to combat financing terrorism, which will be gradually implemented by the CLS. The KYC Program applies to both natural persons and legal entities (partnerships, corporate, trusts, a legal arrangement with a structure or functions similar to trusts or any other legal entity).
In order to open an account through the NetLeaders website the user must provide the CLS with the following data:
Customers who open an account as natural persons may not appoint any representatives/proxies and must act personally toward Netleaders.
Before signing up as an Advocate or purchasing any License on NetLeaders, each account user has to provide Netleaders with additional personal data which will be the subject of verification. The additional data is the following:
In the case of legal entities, CLS shall inquire if there exists any beneficial owner in relation to a customer. To that end CLS shall ask the customer to provide relevant data and documents which confirm the veracity of the data. A beneficial owner means the natural person who ultimately owns or controls the customer or the natural person on whose behalf a transaction is conducted or business relations are established, and includes any person who exercises ultimate effective control over a legal entity. In some cases CLS may refrain from identification and verification of the beneficial owners, for instance where the customer is a company listed on a stock exchange or financial institution.
In case it is proven that the above documents are particularly difficult to obtain in the customer’s country of residence, CLS may refrain from the review of the above documents and may instead require a review of other documents which are typically used in the customer’s place of residence. By way of an example, if none of the above documents is issued in the customer’s name but they are issued in their spouse’s name, CLS may accept a review of such documents issued in the spouse’s name together with a proof of marriage.
In order to purchase a License and use DasEcosystem services, the customer’s identity will be checked against commonly recognized sanctions lists, in particular the list published by the Monetary Authority of Singapore.
Where the customer is not a natural person, the CLS shall enquire as to the nature of the customer’s business and its ownership and control structure, the legal form, constitution and powers that regulate and bind the legal entity. To that end CLS shall ask the customer to provide relevant information and documents.
The customer will be allowed to take advantage of the DasEcosystem products and services only upon successful verification of the customer’s identity.
Netleaders shall determine if a customer, any natural person appointed to act on behalf of the customer, any connected party of the customer, or any beneficial owner of the customer is a politically exposed person, or a family member or close associate of a politically exposed person.
All employees and officers of NetLeaders in any way involved in the KYC process or in any financial matters will receive ongoing broad-based KYC/AML training as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and compliant with all pertinent laws and regulations. New employees will receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and dates will be maintained. In addition, our compliance training program will be updated as necessary to reflect current laws and regulations.
Our Chief Compliance Officer (“CCO”) will be responsible for leading the development and enforcement of compliance policies and procedures for our KYC Program. Our CCO will also be responsible for reporting any violations of our KYC Program. In addition, the CCO will be responsible for performing a KYC Program audit at least once every twelve (12) months.
Netleaders shall establish the nature and constantly monitor the business relations with the customers. Netleaders may suspend a customer’s account or particular transaction if it knows, suspects or has reason to suspect suspicious activities have occurred on the customer’s account on the NetLeaders platform. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities, or personal means. The CCO will review and investigate suspicious activity to determine if sufficient information has been collected to notify the appropriate authorities. The CCO will maintain records and supporting documentation of suspicious transactions and account histories.
The CCO shall report promptly to the CEO and the Board of CLS all cases of suspicious transactions and the applied measures. Once a year, the KYC/AML report shall be presented to the Board by the CCO. All records and documents relating to KYC/AML will be retained for at least 5 years following the termination of a Netleaders account and will be readily available upon request by the competent authorities. However, information pertaining to a matter under investigation or which has been the subject of a suspicious transaction report shall be stored as long as requested or ordered by the relevant Singapore authorities.
We may adjust this KYC Policy if the law or our policy changes. We recommend that you regularly review the KYC Policy when you visit our website. You can find a link to the latest version of our KYC Policy in the footer of our website, and in the “Media” section in your dashboard.
The latest version of this policy is EN-49nOt6l18 applicable since 19 September 2018.