Due Diligence Policy
1. Introduction
This Due Diligence Policy sets out the standards and processes by which Seneri conducts due diligence on its sellers, buyers, and partners. This policy ensures that Seneri operates in a legally compliant, transparent, and ethical manner. It applies to all users of the marketplace, as well as business partners, including suppliers and service providers.
2. Purpose
The purpose of this policy is to:
- Mitigate legal, financial, and reputational risks to Seneri.
- Ensure that all users comply with applicable laws, including anti-money laundering (AML), counter-terrorism financing (CTF), and product safety standards.
- Protect the integrity of the marketplace by ensuring that only legitimate sellers and buyers participate in transactions.
- Promote a safe and
trustworthy platform for the sale of clothing, fashion accessories, and
pet items.
3. Scope
This policy applies to:
- Sellers listing items for sale on Seneri.
- Buyers purchasing items on the platform.
- Partners such as suppliers, logistics
providers, and payment service providers.
4. Due Diligence Process
4.1 Seller Due Diligence
Before a seller is approved to list products on the marketplace, the following steps will be undertaken:
- Identity Verification: Sellers must provide valid identification and complete the registration process, which includes verifying personal information such as name, address, and contact details.
- Compliance Check: Sellers will be reviewed against regulatory lists, including sanctions and watchlists, to ensure they do not pose any AML or CTF risks.
- Product Compliance: Sellers will be required to ensure that their products comply with Seneri’s policies, including prohibiting the sale of restricted items such as alcohol, medicine, high-value gold, gems, and other high-risk items.
- Background Check: A thorough review of the seller’s previous selling history and feedback from other platforms (if applicable) will be conducted to assess their reliability and legitimacy.
4.2 Buyer Due Diligence
While buyers on Seneri are not required to undergo the same level of due diligence as sellers, the following steps will be taken to prevent fraud and misuse of the platform:
- Identity Verification: Buyers will be required to provide basic personal information and verify their email addresses or phone numbers to create an account.
- Transaction Monitoring: All buyer transactions will be monitored for unusual or suspicious activity, and any flagged transactions will be reviewed by Seneri’s compliance team.
- Fraud Prevention: Buyers exhibiting fraudulent behavior (e.g., filing false claims, engaging in money laundering) will be subject to further investigation and potential suspension from the platform.
4.3 Partner Due Diligence
All partners working with Seneri (e.g., logistics, payment processors) will undergo a due diligence review to ensure they meet Seneri’s standards:
- Partner Verification: Partners will be required to provide valid business credentials and licensing information, as well as details of their operations and compliance with applicable laws.
- Financial Stability: A review of the partner’s financial statements or credit ratings may be conducted to assess their stability.
- Reputation Check: Publicly available information, reviews, or feedback from other clients will be reviewed to ensure the partner has a good reputation.
5. Risk-Based Approach
Seneri will adopt a risk-based approach to due diligence, which means that higher-risk users and transactions will be subject to more stringent checks. Risk factors include:
- High-Value Transactions: Transactions involving significant sums of money may require additional verification.
- Geographic Risk: Sellers or buyers located in jurisdictions with higher risks of financial crime will be subject to enhanced due diligence.
- Product Risk: Items with a high potential for fraud or regulatory violations (e.g., luxury goods) will be more closely monitored.
6. Ongoing Monitoring
- Transaction Monitoring: Seneri will monitor transactions and user activity for any suspicious or unusual patterns. Automated tools may be used to flag high-risk behavior.
- Periodic Reviews: Sellers and partners may be subject to periodic reviews to ensure continued compliance with Seneri’s policies and applicable laws.
- User Reports: Seneri will allow users to report suspicious activity, such as counterfeit goods or fraudulent transactions, which will trigger an investigation.
7. Reporting and Record Keeping
- Documentation: All due diligence steps will be documented and stored securely. This includes identity verification records, background checks, and transaction monitoring data.
- Reporting: In case of suspected illegal activities, Seneri will report the relevant details to the appropriate authorities, in compliance with AML and CTF regulations.
- Retention of Records: Seneri will retain due diligence records for a minimum period of five years, in line with legal requirements.
8. Breaches of the Due Diligence Policy
- Enforcement: Sellers or buyers found in breach of this policy may face penalties, including account suspension or permanent removal from the platform.
- Legal Action: Seneri reserves the right to pursue legal action against any users engaging in illegal activities or violating the terms of this policy.
9. Review and Updates
This policy will be reviewed annually, or whenever there are significant regulatory changes, to ensure it remains up to date with legal requirements and industry best practices.
10. Contact Information
For any inquiries related to Seneri’s Due Diligence Policy or to report suspicious activities, please contact us at:
- Email: info@seneri.com