MUSIC ALLIGATOR LTD

AML/KYC Policy

Original Credit Transaction (OCT) allows our Company to optimise direct payouts (streaming fees) to artists/labels (the Users). While payouts can be facilitated through OCT, they must meet tax legislations of the United Kingdom. This way direct payments can be made to artists payment cards significantly simplifying the process and reducing costs. The payout amounts depend on the number of plays/downloads of his track


AML & KYC POLICY

Having regard for the safety of the users and due to the legal requirements, The European Union, The United Kingdom and other countries, MUSIC ALLIGATOR LTD has implemented and started to use KYC policy (customer's identification), AML / CTF (combating money-laundering and terrorist financing) as it is required from banks and other financial institutions.

The purpose of those policies is an effective combating of money-laundering and terrorist financing (AML / CTF) on our platform by proper identification of actual users of our accounts and supervision of OCT transactions. We shall identify and cease transactions made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviours

Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to users some of the general rules and stipulations of our policies which directly concern users and affect the services we render.


USER'S IDENTIFICATION

In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to accept payments from our website. This is the reason why we collect scans of IDs, the authenticity of which is verified by our AML Officer.

All participants of transactions shall provide AML Officer with the necessary documents, such as proof of identity and proof of address, as well as any other documents if necessary.

Identity Proof (Passport, Driving License)

Address Proof (Passport, Electricity Bill, Bank Account Statement, Gas Bill, Lease agreement along with last 3 months, rent receipt)

We require sending “selfie” or the User's recording with ID document in order to preclude the possibility of using the User's documents by someone else. Verification of the User's likeness to the photo from the User's ID is done manually by our customer support services.

In case of any doubts, our customer support team will contact the User to explain any concerns and solve the issues that arose.

If we cannot determine, beyond a reasonable doubt, that the documents the User provided belong to you and are the authentic we won’t be able to let the User execute any transactions.


USER’S IDENTIFICATION – COMPANIES

In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company.

Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such users is doing “manually” and is considerably more time-consuming.


TRANSACTIONS’ MONITORING AND SUPERVISION

Using our proprietary software we also analyse all transactions that take place on our website looking for suspicious and unusual behaviours. If our AML specialists determine that the provided information does not clarify our doubts, we will be obliged to end our cooperation with the User or even report the User’s transactions to relevant authorities.


ADDITIONAL VERIFICATION

In some cases, we can require additional documentation proving real, exact place of residence, education and occupation of the User.


BASIC AM / CTF RULES

Our operating rules include inter alia as follows:

MUSIC ALLIGATOR LTD does not allow any exceptions in the field of documentation required from users.

MUSIC ALLIGATOR LTD reserves the right to refuse to process the User’s transaction at any time, in case of suspicion of AML / CTF risk.

In accordance with the international law, we are not obliged (or even forbidden) to inform our clients, if we report their behaviours as suspicious to relevant authorities


SANCTIONED COUNTRIES

In accordance with our policies we do not open accounts and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission) impose high AML / CTF high risk.

Currently, these countries are:

Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russia, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states).

The user should remember that this model is a result of the work and experience of our AML team and can be changed as the legal requirements of countries changes as well as a result of gaining new knowledge and experience. In particular transition, limits may change due to periodical audits and verification of efficiency of our procedures. We will keep you updated if any changes would influence your situation.


AML Officer:

Signature:

Date: 02.05.2022