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The prevention of money laundering and terrorist financing is of utmost importance to ecrop. We have implemented a robust anti-money laundering system that complies with the requirements of the Money Laundering Act (GwG), EU Money Transfer Regulation, and the recommendations of the Financial Action Task Force (FATF). Our risk-based approach, which includes regular risk assessments and compliance with strict KYC/AML processes, ensures effective and efficient prevention of money laundering and terrorist financing.

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Risk-Based Approach:

ecrop follows a risk-based approach in accordance with § 4 GwG, which is oriented towards the company’s individual risks. We conduct regular, risk-based money laundering risk assessments. These include all relevant risk factors, such as:
  • Risk Assessment: We conduct regular, risk-based risk assessments. These include all relevant risk factors, such as:
    • Customer Groups: Identification and assessment of risks posed by different customer groups, e.g., PEPs, companies from high-risk countries.
    • Products and Services: Analysis of money laundering risks associated with offered products and services.
    • Transaction Types: Assessment of risks posed by different transaction types, e.g., large cash deposits, complex transaction structures.
    • Geographic Factors: Consideration of risks arising from countries where ecrop operates or has customers.
    • Technology: Assessment of risks associated with used technology, e.g., software vulnerabilities, anonymization possibilities.
    • Additional Risk Factors: In addition to legally required risk factors, ecrop considers other relevant aspects, such as current cybercrime threat levels or results of internal and external audits.
The results of the risk assessment are documented and incorporated into the design of preventive measures.

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KYC Processes (Know Your Customer):

ecrop applies strict KYC processes to verify the identity of all customers in accordance with § 10 GwG and the requirements of CryptoAssetTransferV. The KYC/AML process includes:
  • Identification: Verification of customer identity using a valid official identification document. ecrop uses Deutsche Post’s Video-Ident procedure (PostIdent), which meets the requirements of the GwG. Link to KYC Partner’s Website
  • Verification: Verification of customer identity through comparison with official databases.
  • Determination of Beneficial Owner: Identification of the natural person who ultimately exercises control over the assets.
  • Clarification of Background and Purpose of Business Relationship: Collection and verification of information about the background and purpose of the business relationship with the customer.

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Transaction Monitoring:

ecrop continuously monitors all transactions in accordance with § 11 GwG to detect and report suspicious activities early. Our monitoring system analyzes transactions in real-time based on defined risk parameters, such as:
  • Transaction Volume: Monitoring of transaction volume and detection of unusually high amounts.
  • Transaction Frequency: Analysis of transaction frequency and detection of unusual patterns.
  • Source and Destination Addresses: Verification of transaction source and destination addresses and identification of addresses associated with criminal activities.
  • Additional Risk Indicators: Use of additional risk indicators, such as the type of cryptocurrency used or involvement with certain trading platforms.
When anomalies are detected, the system automatically generates alerts that are reviewed by our compliance officer and reported to the Financial Intelligence Unit (FIU) if necessary. ecrop has established a process with suspicious activity reporting procedures for this purpose.

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Organizational Obligations:

  • Money Laundering Reporting Officer: ecrop has appointed a money laundering reporting officer responsible for implementing and monitoring the anti-money laundering system. The officer is independent, autonomous, and reports directly to management. Contact: gwg@ecrop.de
  • Training Requirements: All ecrop employees involved in money laundering-relevant activities receive regular training on anti-money laundering topics. The training includes:
    • Fundamentals of GwG and CryptoAssetTransferV.
    • Internal policies and procedures of ecrop.
    • Detection and reporting of suspicious transactions.
    • Data protection and data security in handling customer data.
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