Unclaimed Funds

Unclaimed Funds

1.  Introduction

This policy outlines the procedures for handling potentially fraudulent money in compliance with Spanish jurisdiction, ensuring adherence to national and European Union regulations concerning anti-money laundering (AML) and counter-terrorist financing (CTF).

2.  Scope

This policy applies to all employees, contractors, and agents of Nebeus who are involved in the provision of wallet and IBAN services.

3.  Definitions

SEPBLAC: The Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses in Spain.

Suspicious Activity: Any transaction or behavior that raises suspicion of money laundering or fraud.

Freezing of Funds: The act of preventing any transactions involving potentially fraudulent funds until further investigation.

4.  Reporting Obligations

All employees must report any suspicion of fraudulent activity to SEPBLAC immediately.

The Compliance Officer must ensure that suspicious activity reports (SARs) are filed without delay.

5.  Freezing of Funds

Upon detecting suspicious activity, employees must immediately freeze the relevant funds to prevent any further transactions.

The Compliance Officer must be notified immediately when funds are frozen.

6.  Investigation Process

The Compliance Officer will coordinate with SEPBLAC and other relevant authorities during the investigation.

All relevant documentation and information must be provided promptly to assist in the investigation.

Regular Audits: Conduct regular audits of the unallocated funds account to ensure transparency and accountability.


Continuous Improvement: Periodically review and update this protocol to incorporate best practices and address emerging fraud risks.

7.  Duration of Holding

Funds must remain frozen until the investigation is concluded and a legal determination is made by the authorities.

If the investigation confirms the funds are fraudulent, they may be subject to seizure and forfeiture as per Spanish law.

8.  Cooperation with Authorities

Full cooperation with SEPBLAC and other relevant authorities is mandatory during the investigation.

Employees must provide all necessary documentation and information requested by the authorities in a timely manner.

9.  Legal Framework

Compliance with Law 10/2010, of April 28, on the Prevention of Money Laundering and Terrorist Financing, and its subsequent amendments, is mandatory.

Employees must be familiar with the relevant provisions of the law and act accordingly.

10.        Penalties for Non-Compliance

Failure to report suspicious activity or improper handling of funds can result in significant penalties, including fines and other legal sanctions.

Disciplinary actions, up to and including termination, may be taken against employees who fail to comply with this policy.

11.        Responsibilities

Employees: Must report any suspicious activity immediately and comply with all aspects of this policy.

Compliance Officer: Responsible for filing SARs, coordinating with authorities, and ensuring compliance with AML laws and regulations.

Management: Ensure that all employees are aware of and trained on this policy and AML regulations.

12.        Training


Regular training sessions on AML and CTF regulations, including the proper procedures for detecting and reporting suspicious activity, will be conducted for all employees.

13.        Review

This policy will be reviewed annually and updated as necessary to reflect any changes in regulations or company procedures.


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