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CLIproxy is committed to maintaining a secure, compliant, and transparent business environment and continuously strengthening its Anti-Money Laundering (AML) and business risk management framework in accordance with applicable laws, regulations, and compliance requirements.
Through internal policies, risk control measures, and customer management procedures, CLIproxy conducts ongoing reviews and monitoring of business activities and regularly updates its policies based on applicable requirements and business developments.
2.1 Customer Due Diligence (CDD)
Basic Due Diligence
Depending on applicable laws, regulations, and the level of risk involved, CLIproxy may require information to identify and verify customers, beneficial owners, controlling persons, and relevant responsible parties.
CLIproxy applies a risk-based approach to customer due diligence:
Low-Risk Customers: Appropriate simplified due diligence measures may be applied.
Medium-Risk Customers: Additional verification of identity, business background, and intended use of services may be conducted based on the assessed risk.
High-Risk Customers: Enhanced due diligence and appropriate management approval may be required based on the level of risk.
For corporate and other organizational customers, CLIproxy may obtain information regarding the nature of the business, business purpose, and relevant responsible persons as appropriate to support risk assessment.
Enhanced Due Diligence (EDD)
For customers presenting elevated business risks, unusual identity information, abnormal service activity, or other circumstances requiring further verification, CLIproxy may conduct additional identity and business verification measures.
2.2 Account and Service Activity Monitoring
CLIproxy conducts ongoing monitoring of account and service activity based on the nature of its business. Monitoring may include unusual account activity, service usage volumes, access frequency, usage patterns, and other activities that may present compliance or security risks.
Where unusual activity is identified through automated systems or manual review, CLIproxy may conduct a three-level manual review process. Depending on the level of risk, further verification, service restrictions, or other appropriate measures may be applied.
2.3 Unusual Activity and Risk Reporting
CLIproxy monitors unusual activity involving accounts and services, including unusual account operations, payment activity, service usage volumes, access patterns, and other activities that may present potential risks.
Where a review confirms that an activity presents a material compliance risk, CLIproxy will take appropriate measures in accordance with applicable laws, regulations, and internal compliance policies. Where legally required or permitted, CLIproxy may cooperate with relevant authorities in investigations or information requests.
2.4 Compliance Screening
CLIproxy conducts periodic screening against relevant publicly available sanctions and restriction lists, including those published by the United Nations, OFAC, the European Union, and the United Kingdom. OFAC maintains its sanctions lists through its official Sanctions List Service.
Where a potential match is identified, CLIproxy may apply appropriate restrictions and initiate further compliance review based on the circumstances.
Governance Structure
CLIproxy maintains an internal compliance management framework. Designated personnel are responsible for coordinating, implementing, and overseeing relevant compliance activities, with risk management procedures continuously improved based on business needs.
Personnel Management
Relevant personnel receive appropriate compliance training based on their responsibilities, including requirements relating to customer identification and the identification and handling of unusual activities. Relevant personnel are subject to periodic assessments.
CLIproxy maintains protected feedback channels, including its website and customer support channels, to receive and address relevant compliance matters in a timely manner.
Independent Review
CLIproxy engages an external compliance audit or review organization to conduct an annual assessment of the effectiveness of its compliance framework.
Customers are required to:
● Provide true, accurate, complete, and valid identity and business information;
● Promptly update relevant information when changes occur;
● Cooperate with identity or business verification conducted by CLIproxy based on applicable requirements and risk assessments;
● Use CLIproxy services in accordance with applicable laws, regulations, and CLIproxy's applicable agreements and policies.
CLIproxy services must not be used for activities that violate applicable laws, regulations, or company policies, including but not limited to:
● Money laundering or other unlawful financial activities;
● Concealing, falsifying, or providing false identity or business information;
● Circumventing applicable laws, regulations, or regulatory requirements;
● Other activities that may create material security or compliance risks.
CLIproxy maintains necessary AML and risk management records in accordance with applicable laws, regulations, and internal compliance policies. Where legally required or permitted, CLIproxy may provide relevant information to competent authorities or submit required reports.
CLIproxy implements reasonable security measures to protect customer information and business data against unauthorized access, use, or processing.
Cross-border data processing is conducted in accordance with applicable data protection and privacy laws, including the GDPR and CCPA, where applicable.
CLIproxy will periodically review and update this policy based on changes in applicable laws and regulations, regulatory requirements, and business operations.
Compliance and Risk Feedback:support@cliproxy.com