The People’s SCE with limited liability (hereinafter the “SCE”) operates a set of web and mobile based software applications that interact with various decentralized blockchains such as eCredits, Ethereum, and other blockchains. The main software application provided by the SCE is the so called “eCredits Wallet App”, which is a non-custodial cryptocurrency wallet interacting with the various blockchains in a way that SCE does not manage or store nor has access to user’s private keys or their crypto-assets. SCE also does not hold in custody, send or receive crypto-assets and cannot access or restore user’s private keys. SCE also does not enable or provide services for the exchange between one or more forms of crypto-assets or any exchange of crypto-assets for FIAT currencies on its proprietary software applications. Any initiated transaction occurs on decentralized blockchain, not controlled by the SCE. In many technical aspects, the “eCredits Wallet App” is similar to the “Metamask app” or “Trust Wallet app” with additional functionalities.
In addition to “eCredits Wallet App”, SCE also provides a set of business-centric web applications based on paid subscription model allowing merchants to access to advanced functionalities to interact with Businesses’ customers through various additional applications such as Web Portal, Cashier App, eActivity Program and other SCE technologies, APIs, access to third-party programs, loyalty and reward systems & services as specified in applicable eWallet general terms and conditions.
It follows from the above that the company SCE, as a provider of “non-custodial wallets” with additional merchant-centric software integrations in a form of mobile and web based applications, does not provide services that would require it to register as a virtual asset service provider (VASP) or other type of entity such as payment service provider, e-money institution, etc., which is obligated pursuant to relevant AML/CFT law to implement regulatory measures to detect and prevent money laundering and terrorist financing under relevant EU regulatory framework. , These conclusions have been confirmed by internal and external independent legal experts.
As indicated above, SCE is not strictly in accordance with the letter of the law, obliged to implement and enforce AML/CFT activities. Notwithstanding the foregoing, it should be noted that professional users (i.e Businesses) and third-party service providers are nevertheless subject to certain verification methods for onboarding clients.
For example, trading in ECS tokens is (at the moment) enabled on the trading platform Blocktrade, which has established AML/CFT verification methods and holds the necessary licences as virtual asset service provider.
The onboarding of “Business” itself directly to The People’s SCE is also subject to some onboarding verification. Among other things, the Business is required to provide the following information when registering a Business Profile in accordance with section 7. (Business onboarding and approval process) of Business Terms of Service ( https://ecredits.com/en/terms-and-conditions-business/):
»7.3 In connection with the Business Profile, you must provide your business information for Users. This information may include:
(a) Legal entity name;
(b) Business email address;
(c) Website
(d) Registered office;
(e) Business address;
(f) Registration number;
(g) Country of registration;
(h) Tax ID/VAT number;
(i) Other information required on the Web Portal.«
The People’s SCE has zero tolerance for money laundering and terrorist financing and strives to prevent it through reasonable measures.
14. October 2022
The People’s SCE with limited liability
1 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (consolidated text).
2 FATF (2019), Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers, FATF,
Paris, www.fatf-gafi.org/publications/fatfrecommendations/documents/Guidance-RBA-virtual-assets.html
3 See: EBA report with advice for the European Commission on crypto-assets, 9 January 2019, https://www.eba.europa.eu/eba-reports-on-crypto-assets4 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (consolidated text)[1] FATF (2019), Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers, FATF,Paris, www.fatf-gafi.org/publications/fatfrecommendations/documents/Guidance-RBA-virtual-assets.html