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AML/KYC POLICY

Last Updated: February, 2024


This document outlines the principles of our “Know Your Customer” (KYC) and “Anti-Money Laundering” (AML) policies, establishing our committed approach to hindering money laundering activities while we cater to our clients.

 

The aim of our AML/KYC Policy is to safeguard against the misuse of our services for money laundering activities, whether deliberate or accidental. The policy emphasizes the importance of thorough efforts to ascertain the actual identity and beneficial ownership of accounts, the origins of funds, the customer's business nature, and the consistency of account transactions with the customer's business profile, amongst other details. This diligence is crucial in enabling us to manage risks effectively.

 

We are dedicated to shielding our clients from fraudulent activities and scams within the realm of crypto assets. Our approach is robust, incorporating the latest recommendations and updated guidelines from the FATF, the European Parliament, and broader financial industry regulators. Our compliance-focused policy is adept at identifying funds associated with illicit activities and safeguarding our clients' assets against hacks, ransomware, and malware attacks. Our toolkit for combating money laundering and its associated risks includes a blend of policy measures and cutting-edge software that monitors transactions for suspicious activity in real-time.

 

Our AML/KYC Policy, alongside our procedures and internal controls, are meticulously crafted to align with all relevant laws and regulations. These measures undergo regular reviews and updates, ensuring they remain effective and reflect the latest regulatory changes as well as the evolution of our business.

 

Glossary:

  • AML Anti-Money Laundering

  • KYC Know Your Customer

  • CIP Customer Identification Program

  • PEP Politically Exposed Persons

  • STR Suspicious Transaction Reporting

  • SAR Suspicious Activity Reporting

 

1. CUSTOMER IDENTIFICATION PROCEDURE (CIP)

 

CIP is performed prior to establishing business relationships. For every customer who undergoes CIP, we will gather specific identification details, employ risk-oriented approaches to authenticate each customer's identity, document the collected identification data along with the methodologies and outcomes of the verification, and ensure that customers are properly informed about our intention to obtain identification information for the purpose of confirming their identities.

 

a. Identification

 

We will collect the following information from the customers, if applicable, from any person, entity, or organization:


 

  1. the full name;

  2. date of birth (for an individual);

  3. the address, which will be residential street address (for an individual) or a principal place of business, local office, or other physical location (for a person other than an individual); and

  4. for an individual, a valid government-issued identification, evidencing nationality or residence and bearing a photograph or a similar safeguard, such as a driver’s license or passport; and for a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument.

 

The customer has an obligation to update all the information if there is any change.

 

b. Customers Who Provide Misleading Information


Once the information is submitted, it is the customer's responsibility to ensure its accuracy, comprehensiveness, and currency. Should there be any reason to suspect that the information provided by the customer is inaccurate, misleading, outdated, or incomplete, we maintain the authority to issue a notice to the customer, demanding rectification of the information.

 

c. Verifying Information


Depending on the risk and within feasible limits, our verification process will be thorough, ensuring we gather all necessary details to confidently understand our customers' true identities. This process involves employing risk-based methods to confirm and record the accuracy of the information obtained about our customers.

 

We've engaged a Third-Party Service Provider, fully aligned with our Privacy Policy, for the processing of our customers' personal data. This provider will scrutinize the received data to: (1) ascertain whether the information is comprehensive enough to reliably confirm the customer's identity, including checking for logical consistency or discrepancies; (2) verify the authenticity of customer-provided documents and cross-check them against the Specially Designated Nationals and Blocked Persons List and other sanction lists.

 

The verification of information will be conducted within a reasonable timeframe, influenced by the account type and the risk associated with the transactions. Should we encounter any dubious information hinting at potential money laundering, terrorist financing, or other suspicious activities, we will consult internally with the firm’s AML Compliance Officer and proceed to file a SAR/STR, adhering to the relevant laws and regulations.

 

d. Lack of Verification


In instances where it's challenging to confidently ascertain a customer's true identity, our course of action will include: (1) seeking supplementary information; (2) refraining from validating an account; (3) placing the account on a blacklist subsequent to unsuccessful efforts to authenticate the customer's identity; and (4) assessing the need to submit a SAR/STR, in alignment with the relevant laws and regulations.

 

e. Enhanced Due Diligence


We engage in thorough Enhanced Due Diligence for all clients or accounts identified as potentially high-risk, requiring additional scrutiny. Our protocols are structured to refuse or cease business engagements with any client if the necessary Enhanced Due Diligence cannot be satisfactorily completed, or if the information obtained significantly jeopardizes our reputational risk.

Enhanced Due Diligence might involve closely monitoring the account for changes in risk classification, updating KYC documentation, among other measures.

Enhanced Due Diligence entails verifying the origin of funds. Acceptable forms of proof for this verification include, but are not limited to, exchange account histories, transaction receipts from cryptocurrency vendors, or evidence of mining activities.

 

2. RECORDKEEPING


We will meticulously record our verification process, capturing all customer-provided identification details, the methods and outcomes of verification, and the handling of any inconsistencies discovered during the verification.

In line with the records from the Third-Party Service Provider utilized for identification, all customer information gathered during the KYC process is encrypted and stored on Amazon servers that comply with GDPR standards, located within the EU.

We commit to preserving all records of customer identification information for five years following the closure of an account. Similarly, we will maintain records of customer identity verification for a duration of five years from the date of documentation.

 

The above-mentioned records can be made available to the competent authorities upon request.

 

3. AML COMPLIANCE OFFICER

 

The designated AML Compliance Officer, officially appointed by our organization, bears the responsibility for the execution and continuous supervision of the AML/KYC policy, as detailed in this document. It is the duty of the AML Compliance Officer to manage and thoroughly inspect all components of our anti-money laundering and counter-terrorist financing efforts. All unusual or suspect actions must be communicated to the AML Compliance Officer.

 

Interactions concerning this Policy with the AML Compliance Officer should occur through compliance.

 

4. MONITORING OF TRANSACTIONS

 

Continuous surveillance is a crucial component of robust KYC protocols. We are familiar with our customers' usual and acceptable activities, enabling us to pinpoint transactions that deviate from their normal behavior. Nevertheless, the level of scrutiny varies based on the account's risk profile, with high-risk accounts requiring more rigorous observation.

 

Our deployment of a Know-Your-Transaction service marks a significant advancement in real-time anti-money laundering measures for tracking cryptocurrency transactions. This focused strategy has equipped our compliance team with the tools to rapidly identify and respond to transactions that involve suspect funds.

 

5. RISK MANAGEMENT

 

We have established suitable measures to guarantee the successful execution of KYC standards. These measures encompass adequate managerial supervision, organizational systems, checks and balances, division of responsibilities, education, and other pertinent aspects. Periodically, the compliance team will conduct essential quality assessments and record examinations to confirm compliance with the KYC norms and practices. Additionally, the compliance team will periodically inform upper management about any concerns encountered during the customer onboarding process.
 

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