1 Measures against money laundering and terrorist financing
1.1 Legislation
Orange Gateway ehf., here after Orange Gateway, operates in accordance with the Act on Measures Against Money Laundering and Terrorist Financing, as subsequently amended. Orange Gateway is required to perform due diligence on customers, upon the establishment of a business relationship, as part of regular control and/or for individual transactions. To perform due diligence, Orange Gateway calls for, among other details, personal information about a customer, including name, Id. No., legal domicile, job title/position, telephone number, email address, place of birth and nationality, in addition to financial information. Legal entities shall provide information about name, Reg. No., legal address, legal form, board of directors, executive board and person authorized to sign, as well as information about the beneficial owners of the legal entity and persons authorized to oblige the entity. Orange Gateway also gathers information about the origin of the funds customers intend to use in transactions with Orange Gateway, whether transactions are undertaken on behalf of a third party and information about the nature and purpose of the intended business relationship and/or transaction.
1.2 Due diligence
As part of due diligence, the customer shall provide proof of identity by showing valid identification issued or attested by a competent authority, e.g. a passport, driver’s license, Icelandic identity card or valid electronic ID. For underage customers, who do not have own personal identification, legal guardians can show their ID. If a business relationship is established on behalf of a legal entity, trust fund or comparable party, all board members, managing directors, authorized signatories and beneficial owners must verify their identity by showing valid identification. The same applies to all owners in a residents’ association when property holdings in multi-family dwellings number six or less. Legal entities prove their identity by providing a certificate from the Enterprise Register of the Directorate of Internal Revenue or equivalent registry as proof of their registration. An assessment shall be made on a case-by-case basis whether to request a copy of a company’s Articles of Association and/or audited annual financial statements.
1.3 Monitoring
Orange Gateway uses risk-based monitoring of contractual relationships with customers and gathers updates to information as and when necessary, at any time during a business relationship. Under certain circumstances and in addition to the above, Orange Gateway is required to apply enhanced due diligence in certain sensitive cases. In such cases, Orange Gateway reserves the right to request additional information, including personal data, about the customer to carry out enhanced due diligence. If Orange Gateway suspects that the funds the customer intends to funnel into Orange Gateway’s systems are earnings from illegal activity and/or linked to terrorist financing, Orange Gateway reserves every right to halt requested transactions without any notice. If Orange Gateway has legitimate grounds or reason to suspect certain transactions of being suspicious with regards to money laundering and/or terrorist financing, Orange Gateway is obliged to report the transaction to the relevant law enforcement authorities and provide all necessary information in connection with the case. Customers are obligated to inform Orange Gateway of any changes to the details submitted to Orange Gateway.
Approved initially on 1st of April 2024