AML Policy
AML Policy and Procedures
The standards described in this AML and KYC Policy are based on applicable legal and regulatory requirements, including the principles set out in the EU Anti-Money Laundering framework, particularly Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.Zeppelin is committed to maintaining high standards of anti-money laundering and counter-terrorist financing compliance. The Company requires its management, employees, and relevant representatives to follow these standards in order to prevent the misuse of its products and services for money laundering, terrorist financing, or other unlawful activities.Zeppelin's AML/CTF compliance framework includes, but is not limited to, the following measures:
- customer identification and verification;
- identification and verification of Ultimate Beneficial Owners, where applicable;
- assessment and classification of AML/CTF risks;
- implementation of internal AML/CTF controls, policies, and procedures;
- enhanced due diligence for higher-risk customers;
- identification of Politically Exposed Persons (PEPs);
- monitoring and reporting of suspicious customer activity;
- screening against sanctions lists, terrorism watchlists, and other applicable restricted party databases;
- ongoing staff training and compliance awareness programs;
- maintenance of relevant compliance records;
- handling regulatory requests, reviews, and incidents;
- day-to-day compliance oversight by designated compliance personnel.
KYC Policy and Procedures
Zeppelin applies strict Know Your Customer (KYC) standards as part of its compliance program. These procedures include the following:
- customer identification and verification;
- customer acceptance and non-acceptance criteria, including restrictions for underage individuals and persons from prohibited or sanctioned territories;
- monitoring of high-risk customers;
- collection of any information relevant to AML risk assessment;
- verification procedures at the time of relevant transactions;
- ongoing KYC checks based on the customer's risk profile and activity.
Withdrawal Method Policy
In line with AML/CTF requirements, Zeppelin applies a payment method matching policy for withdrawals.Withdrawals must, where possible, be made using the same payment method that was used for the original deposit. If a customer has used more than one deposit method, withdrawals may be processed proportionally according to the deposited amounts or in another order determined by the Company at its sole discretion.The Company reserves the right to request additional documentation to verify ownership of the payment method before approving any withdrawal.Withdrawals to payment methods that have not previously been used for deposits will not be allowed unless expressly approved by the Compliance Officer.
Risk-Based Approach
Zeppelin follows a Risk-Based Approach (RBA) when assessing AML/CTF exposure and determining the level of due diligence required for each customer.As part of this approach, the Company may:
- conduct screening before processing transactions to ensure that the customer is not linked to criminal activity, sanctioned entities, or terrorism-related lists;
- collect relevant customer information before completing a transaction;
- assess customer risk based on factors such as background, country of origin, source of funds, transaction size, and transaction frequency;
- apply enhanced due diligence measures to customers identified as high-risk;
- carry out additional checks in cases involving unclear source of funds, unusually large transactions, or frequent transaction activity.
Client Identification
The customer identification process is carried out:
- before any financial transaction is completed;
- whenever there is doubt regarding the authenticity, accuracy, or adequacy of previously collected identification data;
- by requesting valid proof of identity and, where necessary, proof of residence;
- without permitting any transaction where identity verification, and where applicable residence verification, remains incomplete.
Politically Exposed Persons (PEPs)
Zeppelin maintains specific controls in relation to Politically Exposed Persons (PEPs).The Company may perform PEP checks at any time and at its sole discretion. If these checks indicate that a customer qualifies as a PEP, Zeppelin reserves the right to terminate the account and return any existing deposits to the customer.In such cases, the Company may, at its sole discretion, apply an administrative fee of up to 20% of the amount transferred.
Required Information
As part of the verification process, customers may be required to provide the following information and documentation:
- full name;
- email address;
- date of birth;
- proof of identity;
- proof of residence.
Compliance Officer
The Compliance Officer is responsible for the effective implementation and ongoing enforcement of Zeppelin's AML/KYC Policy.The responsibilities of the Compliance Officer include:
- collecting and reviewing customer identification information;
- monitoring customer transactions and account activity;
- developing and maintaining internal policies and procedures for the preparation, review, filing, and retention of reports and records required by competent authorities;
- maintaining AML/KYC records and documentation;
- providing information to law enforcement and regulatory authorities where required by applicable law;
- communicating with competent authorities involved in the prevention of money laundering, terrorist financing, and other illegal activities;
- overseeing AML/KYC staff training and awareness.
