MEEG service AML policy

MEEG, in response to concerns by regulators in many countries about the potential use of cryptocurrencies for money laundering purposes, and recognising the complete anonymity of transactions as contrary to the interests of its customers, adopts this Money Laundering and Terrorist Financing Program on the following


1. terms and definitions

1.1 In the Money Laundering and Terrorist Financing Prevention Programme,

unless expressly provided otherwise in the text, the following terms shall have the meanings as specified below:

- "Laundering of proceeds of crime" means giving a legitimate appearance to the possession,

use or disposal of money or other property obtained through the commission of an offence.

- "Service" - MEEG

- "Agreement" - User Agreement, the text of which is available at

"User" means an individual who is legally capable under applicable law and who has entered into an Agreement with the Service.

- "Programme" means this Money Laundering and Terrorist Financing Prevention Programme.

- "Public Officials" - persons holding public office and civil service positions (including heads of state, governments, ministers, heads of departments, heads of central banks, supreme court judges, prosecutors, ambassadors, heads of public corporations and foundations, members of parliaments).

- "Terrorist financing" is the provision or collection of funds or financial services with the knowledge that they are intended to finance the organisation, preparation and commission of a terrorist act.

1.2 All other terms and definitions in the Program text shall be interpreted in accordance with the Agreement and the applicable Ukrainian legislation.

1.3. The titles of the headings (articles) of the Program are intended solely for the convenience of using the text of the Program and have no literal legal meaning.


2. Validity of the Program

2.1 The provisions of the Program are binding on the Service and the Users.

2.2 The Service provides services to the Users only under the condition that the Users comply with the Program.


3 Refusal to cooperate

3.1 General rule

3.1.1 The Service disclaims any responsibility to the User if it becomes aware that the User is trying to use the Service in any way for illegal activities, including money laundering and terrorism financing.

3.2 Private cases

The Service disclaims any responsibility to the User if it would require the User to take any actions for the benefit of persons

3.2.1. suspected or accused of, or convicted of terrorist or extremist activities;

3.2.2. against whom international or regional sanctions have been imposed;

3.2.3. on whom actions to freeze (block) monetary funds and other assets have been or shall be applied

3.2.4. who are public officials found guilty of violating human rights; 3.2.5;

3.2.5. are nationals of states on which international sanctions have been imposed.


4 Limitations on transactions

4.1 If there is a reason to suspect that the User has engaged in illegal activities in accordance with paragraph 3.1.1 of the Program, the Service reserves the right to terminate any transaction for the benefit of such User at any time.

4.2 The Service reserves the right to block the transactions until the User identified by the Service in accordance with the provisions of the Article 5 of the Program has provided

additional documents for the identification of the Beneficiary or the Beneficial owner,

to clarify the grounds for transaction and other circumstances

(the package of necessary documents is defined by the Service in every specific case) if

4.3. the Service has grounds to consider the transaction carried out by the User as suspicious or unusual.

4.4 In case the documents requested have not been provided by the User or the Service has doubts on the veracity of the information contained in them, the Service reserves the right not to conduct the transaction or to suspend the transaction until the appropriate documents are provided.


5. Identification of Users

5.1 For the User identification, the Service ascertains the following information about the User

5.1.1. full name;

5.1.2. address of the place of residence (registration);

5.1.3. date and place of birth;

5.1.4. details of the identification documents.

5.2 The User is identified by presenting a scanned copy/photo of their passport or any other document proving their identity, and a copy/photo of the document proving their place of residence.

If necessary, the Service may request other documents from the User which are necessary to satisfy the requirements of the Program.

5.3 The Service demands that the Users who are foreign or Ukrainian public officials, or the spouses or minor children of such persons inform the Service before carrying out any operations with the Service.

In case the Service finds out that the User has hidden this information, the Service has the right to terminate any actions in favour of such Users.


6. Requirements for the documents

6.1 Documents provided by the User to the Service in accordance with the paragraphs 4.2-4.3 of the Program must be written in their native language, in case of translation such translation must be certified by the notary.

6.2 Scanned copies of documents must be submitted in high quality with a resolution of at least 300dpi.


7. Measures taken by the Service

To ensure compliance with point 2.1 of the Program, the Service takes the following measures:

7.1 Appoint an employee responsible for compliance with the Program, updating the Program and its compliance with international standards and Ukrainian legislation;

7.2 Establishes the criteria for doubtful and unusual transactions, as well as ways to identify doubtful and unusual transactions;

7.3. Analyzes transactions conducted by Users in terms of their compliance with the criteria of doubtful and unusual transactions;

7.4 Keep records of Users' transactions and retain information on such transactions for a period of 5 (five) years;

7.5 Checks at least once every 3 months whether the persons specified in clause 3.2 of the Programme are among the Users.


8. Changes in Program Terms

8.1 The Service may modify the Program, including the introduction of new requirements and limits, unilaterally.

The Service announces adoption of the new version of the Program by posting a news announcement on the Internet site at

At the same time, the new version of the Program comes into effect after 3 (three) days from the moment of its posting on the Internet at

8.2 Users are obliged to acquaint themselves with the new version of the Program.

Continued use of the Website at will constitute User's acceptance of the terms of the new version of the Program.

8.3. If the User does not agree to the terms and conditions of the new version of the Programme, the User shall discontinue using the Website and the System.