Devolve Developer “Anti Money Laundering and Know Your Client” Policy


1.0      Introduction

To avert the use of Devolve token (DVX)  and Devolve Developer products and services for illegitimate purposes, Devolve Developer designed a policy to prevent and mitigate the risk of being involved in illegal activity. The Devolve Developer “Anti-Money Laundering and Know Your Client” (AML/KYC) Policy is a key component in the program to prevent and detect money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, bribery fraud and identity theft and to take action in case of any form of suspicious activity from its Participants.

Understanding that AML/KYC is an ongoing, risk‐based process we have implemented an effective internal procedural system of identifying participants of Devolve Developer token sale and platform and verifying the Participant’s identity on the basis of documents, data or information in order to detect suspicious activities according to AML/CTF regulation, meet other legal and regulatory obligations, determine the Participant’s residence and/or location, and prevent fraud.

The AML/KYC Policy embraces the following subjects:

  1. Registration process
  2. Verification process
  3. Non-compliance process
  4. Compliance Officer
  5. Monitoring Transactions
  6. Risk Assessment


2.0      Registration process

Participants shall provide the following information to Devolve Developer upon registration:

  • full name;
  • in regards to legal entities, partnerships, foundations or trusts (‘​legal entity’) the full name of the Participant’s representative and the legal entity name);
  • email address; and
  • country of residence.

By agreeing to the Devolve Developer Terms of Use (the “​ Terms​ ”) the Participant will further certify that:

  • the Participant’s name (and the Participant’s business name – for legal entities) and country of residence are correct and the Participant did not use false identity, impersonate another person or otherwise are involved in the prohibited practices (as defined in the Terms);
  • The Participant has full power and authority to enter into the agreement with Devolve Developer;
  • the Participant, who is an individual, is the owner of his/her payment account and the ultimate beneficial owner of the purchased DVX tokens; and
  • the Participant or the legal entity the Participant represent do not reside in any of the restricted territories (as defined in the Terms).


3.0      Verification process

Devolve Developer customer due diligence (“CDD”) verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.  Devolve Developer may retain a verification ranking system such as a simple account, moderate account, complex account, etc. based on the information and documentation provided by Participants. Ranking may affect the amount of DVX a Participant can purchase and or the Participant’s right to withdraw, and/or the level of access to programs on the platform.

The identity verification procedure requires Participants to provide Devolve Developer with reliable, independent source documents, data or information.  For such purposes Devolve Developer reserves the right to collect Participant’s identification information for the AML/KYC Policy purposes.

After the registration process and the purchase of DVX tokens, the Participant will complete the AML/KYC process in the ‘Verification’ section of the dashboard by uploading the required documentation and completing the verification form.  At any time and at its sole discretion Devolve Developer may request by the account dashboard the following:

Required documentation:

  • the Participant’s proof of identity;
  • the Participant’s proof of address; and /or
  • the Participant to perform online video verification.

Verification form requires the Participant’s:

  • postal address;
  • date of birth;
  • phone number; and
  • if required, additional information requested by Devolve Developer to complete the verification process.

Devolve Developer will take steps to confirm the authenticity of the documentation and information provided by the Participant. Legal methods for double-checking identification information will be employed and Devolve Developer reserves the right to investigate Participants who are deemed to be risky or suspicious.

Devolve Developer reserves the right to verify Participant’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Participant). In addition, Devolve Developer reserves the right to request up-to-date documents from the Participant, regardless of their verification status currently or in the past.

Participant’s identification information will be collected, stored, shared and protected strictly in accordance with the Devolve Developer’s Privacy Policy and related regulations. Once the Participant’s identity is verified, Devolve Developer will remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.


3.1      Identity verification

Copies of the documents provided (whether scanned, photographed, etc.) must be of high quality and the edges of the documentation are clearly visible. Documentation provided as evidence of identity must follow one of the valid government issued photo ID listed below:

  • international passport (cover and data pages with photo);
  • national ID card (with photo only, both sides required); or
  • permanent driver’s license (with photo only, both sides required).

Documentation validating the address must follow one of listed documentation below that is not older than 3 months and includes the Participant’s full name and address:

  • utility bill (including electricity, water, gas, landline phone), Internet provider service or cable TV bill;
  • bank statement;
  • tax return accepted by the tax authority;
  • property tax bill;
  • election/Voters ID; or
  • official government letters

In the event the Participant is a legal entity additionally documentation may be requested as follows:

  • formation documents;
  • information sufficient for Devolve Developer to determine the legal entity’s good standing, the authority of the Participant’s representative to act on its behalf, as well as the representative’s identity; and/or
  • information and documents sufficient for Devolve Developer to identify and verify the beneficial owner, including, the ownership and control structure of that legal entity and the KYC information and documents in regard to the beneficial owner.


3.2      Enhanced verification

In certain cases (including, but not limited to when the Participant’s transactions has reached a certain threshold determined by Devolve Developer; in case of suspicious activity or doubts of veracity or adequacy of provided information and documents; or when Devolve Developer has suspicion or information that the Participant has been involved or might be involved in illegal or prohibited activities) Devolve Developer, at its sole discretion, may request the Participant to provide:

  • source of funds information and information on the level of legitimate income, including but not limited to copy of a recent credit / debit / bank account statement (no older than 3 months old);
  • certain documents to be certified by a notary public, and/or
  • two forms of identification, both of which must be government issued and contain a picture and signature.

The source of fund documents shall provide evidence that identifies the actual source(s) of funds that the Participant used to purchase DVX tokens and that it can substantiate the Participant’s buying activity. The source of funds information may be in the form of:

  • proof of earnings (e.g. payslip/director remuneration/dividends/pension);
  • a bank statement/savings account that clearly shows consistent incoming values from an identifiable source;
  • a trust deed clearly showing a consistent entitlement to funds;
  • dated proof of an award/payment made to the Participant; and/or
  • other clear evidence that would support ‘affordability’ in relation to the Participant’s purchasing activities with Devolve Developer


4.0      Non-compliance process

Devolve Developer will refuse to enter into or continue relationships or conduct transactions with a Participant who does not provide the requested information and documentation or provides false, inconsistent or conflicting information where the inconsistency or conflict cannot be resolved after reasonable inquiry.

Devolve Developer may suspend the Participant’s account, the DVX tokens will not be distributed to the Participant or the Participant will not be able to withdraw their DVX tokens until Devolve Developer is able to obtain the requested information and/or documentation and the KYC process is completed satisfactorily. If the Participant does not complete the KYC identification or verification Devolve Developer will refund the Participant’s funds subject to the provisions of the Terms and Conditions, this AML/KYC Policy and applicable laws.

If as the result of the AML/KYC measures it appears that the Participant:

  • has not supplied the requested information and/or documentation to Devolve Developer and/or if Devolve Developer is unable to satisfactorily identify the Participant and/or verify the Participant’s source of funds (when requested) within a reasonable time-period, determined by Devolve Developer;
  • is a resident of restricted territory (as defined in the Terms and Conditions);
  • is under age or is not eligible to enter into an agreement with Devolve Developer;
  • has used representatives, relatives, associates, affiliates, related parties, connected persons and/or other third parties to purchase DVX token on the Participant’s behalf; and/or
  • has been directly or indirectly participating in any form of prohibited practices or other activities that Devolve Developer considers to constitute a misuse of its offer or breach of its terms,

Devolve Developer, may, as the case may be conduct all or any of the following:

  • refund the Participant’s funds, unless it has to be withheld or forfeited due to the Terms and Conditions or applicable laws;
  • suspend or close the Participant’s account with Devolve Developer;
  • terminate the agreement (the Terms and Conditions) with the Participant; and/or
  • report any criminal or suspicious activities to the appropriate authorities


5.0      Compliance Officer

The Compliance Officer is the person, subcontractor or organization duly authorized by Devolve Developer, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Devolve Developer’s anti-money laundering and counter-terrorist financing, including but not limited to:

  1. Collecting Participants identification information;
  2. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
  3. Monitoring transactions and investigating any significant deviations from normal activity;
  4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
  5. Updating risk assessment regularly;
  6. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.


6.0      Monitoring Transactions

The Participants are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Devolve Developer relies on data analysis as a risk-assessment and suspicion detection tool. Devolve Developer performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  1. Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  2. Case and document management.

With regard to the AML/KYC Policy, Devolve Developer will monitor all transactions and it reserves the right to:

  • ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
  • request the Participant to provide any additional information and documents in case of suspicious transactions; and
  • suspend or terminate User’s Account when Devolve Developer has reasonably suspicion that such User engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor Participant’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.


7.0      Risk Assessment

Devolve Developer, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Devolve Developer is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

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