Since March 2020, Grupeer has suspended all payments to investors. If you still don’t know what happened with Grupeer, make sure you read all about it on the Grupeer Armada website.
Know Your Client Questionnaire
In 15th June 2020, Grupeer posted a new blog post and notified by email all investors that in order to “contribute to a transparent financial system, i.e., observing Anti Money Laundering (AML) and Know Your Client (KYC) policies effective in European Union (EU)”… …” legal counsels have updated the KYC procedure and there is an updated KYC questionnaire published in the Investor’s cabinet as of today. We kindly ask you to fill it or update until 30.06.2020.”
Looking back to Kuetzal and Envestio, there is a clear risk of our personal data to be misused. However, we need to question the true reasons behind this strange request.
What does Grupeer explains?
In the KYC procedure FAQ, Grupeer states that this is a simple compliance step with Anti Money Laundering (AML) and Know Your Client (KYC) policies. But they also state that “It is also required by the banks to renew operations of our accounts, so we can ensure payments to investors.“
Grupeer accounts are currently frozen. Any step that helps Grupeer unlock their bank accounts can compromise investors efforts towards recovering any of the funds still available. But of higher importance for investors is the answer to the question: “What will happen if I will not update or submit my KYC?“
“If you don’t provide KYC information, unfortunately, we might face difficulties to ensure repayment of your deposit.”Grupeer on KYC Questionnaire FAQ
Is all this simply an excuse not to pay investors their money back?
Should you comply or not?
Now… you have 3 options: option a) answer the KYC questionnaire truthfully (that is hard due to the bad quality of the questionnaire, making it almost impossible to fill correctly, but let’s check that later…); option b) answer the KYC questionnaire with inaccurate information; option c) ignore and not comply with the KYC questionnaire request.
If you decide on option c) Grupeer will have ground to deny any withdraws from your account. If you decide on option b) it seems hard to believe that providing slightly inaccurate answers to this KYC would give Grupeer any legal grounds for denying withdrawals. However, if it just is used as an excuse for denying withdrawals, without any legal grounds, the situation remains pretty much the same as it is has been up to now.
So… let’s go for option a) and see what happens!
The questionnaire is so badly prepared that you actually need to reflect on what makes sense in some of the questions as a reply. But you fill the entire KYC questionnaire and reach the submit button. What happens? You get the following message on your screen…
“By submitting the form hereby I confirm that all provided information is correct and true. I undertake to immediately inform Grupeer Limited of any changes in this data and provide updated information in writing. Grupeer Limited is entitled to request and the Investors shall timely provide any information and documents, confirming details provided in the application form. Hereby I confirm that I am aware of the liability, including criminal responsibility for providing false data or wilful non-disclosure of information. I agree that Grupeer Limited has the right to check the reliability of provided information, also I agree that in case of ascertaining that provided information is incomplete or doubtful, it is a sufficient ground for refusal or termination of the business relationship.
After pressing the button “Confirm” you will not be able to change your personal data until the identification process is completed. Please confirm your application.”Grupeer Statement at the end of the KYC questionnaire
If you read carefully, there is really no way for you, as an investor, to win, right? Basically, Grupeer gives themselves the power to refuse investors their funds if they find ground to state that the submitted information is inaccurate or false.
Remember that above I stated that some of the questions were so badly written that you need to imagine what the right answer should be… Maybe that is on purpose, to ensure that you even doing your best to answer truthfully, they will find ground to deny the validation of your account and deny you your funds.
Reflection on a Bad Outcome
This is a strange game for me… being an honest men makes you believe that everyone else is. Grupeer is not being honest acting this way. If you refuse to answer, they will refuse your funds. If you answer with inaccurate or false information, they will refuse your funds. If you do your best to answer truthfully, due to the bad quality of the questionnaire, they can still refuse you your funds.
So… having no alternative, you need to find a way to prove that you are doing your best to comply with their request and document that someway. The best alternative is simply email Grupeer to [email protected] with a message stating that you have done your best to comply with their demand, and are available to clarify any additional questions or provide any additional documentation they need to validate your KYC questionnaire.
This action will not block the possibility for Grupeer to deny you your funds, but will give you proof that can be later used in court to demonstrate your willingness to answer trustfully and only by Grupeer bad faith the process remained frozen.
Taking into consideration all the aspects described above, Grupeer is clearly looking for a way to justify retaining investors funds or deny any future withdrawals. The sad reality is that if you, as an investor, wish to see justice done and push for the recovery of part of your investments, the legal action currently being managed by the Grupeer Armada is your best option.
This only shows that Grupeer is learning from Kuetzal and Envestio tragedies. We, as investors, should do the same, as Killer Mike urged protesters to do in Atlanta: “plot, plan, strategize, organize and mobilize“. Then act!