AML/KYC Policy

This Anti-Money Laundering and Know Your Customer (AML/KYC) Policy describes the measures taken to prevent the platform from being used for money laundering, terrorist financing, or other illegal activities. We are committed to complying with all applicable AML/KYC laws and regulations [4].

Purpose

The purpose of this policy is to:

• Establish a framework for AML/KYC compliance [1].
• Prevent and detect money laundering and terrorist financing [1][8].
• Verify the identity of customers [2][6].
• Monitor customer transactions [6].
• Report suspicious activity to the appropriate authorities [1].
• Ensure compliance with applicable laws and regulations [4].

Customer Due Diligence (CDD) / Know Your Customer (KYC)

We perform Customer Due Diligence (CDD) to verify the identity of our customers [2]. This process, also known as Know Your Customer (KYC), involves collecting and verifying information about our customers before providing services to them [2][6].

The CDD/KYC process includes the following steps:

• Customer Identification: Collecting information to identify the customer, such as name, address, date of birth, and other identifying information [2]. For business entities verifying they are a real entity and knowing the details of its beneficial owners [2].
• Identity Verification: Verifying the customer's identity using reliable and independent sources, such as government-issued identification documents or other official records [2].
• Ongoing Monitoring: Monitoring customer transactions for suspicious activity and updating customer information as needed [6].

Risk Assessment

We assess the money laundering and terrorist financing risks associated with our customers and services [2]. This risk assessment is used to determine the appropriate level of CDD/KYC to be performed.

Customers are categorized into risk levels:

• Low Risk: Customers who pose a minimal risk of money laundering or terrorist financing [6]. Simplified Due Diligence (SDD) may be applied [6].
• Medium Risk: Customers who pose a moderate risk of money laundering or terrorist financing. Standard CDD/KYC procedures are applied [2].
• High Risk: Customers who pose a higher risk of money laundering or terrorist financing [6]. Enhanced Due Diligence (EDD) is required [6]. This includes transaction monitoring, PEP screening, and checking sanctions and watchlists [6].

Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is performed for customers who are identified as high risk [6]. EDD involves additional scrutiny and verification measures to mitigate the risk of money laundering and terrorist financing [3].

EDD measures may include:

• Obtaining additional information about the customer's identity and business activities [2].
• Verifying the source of funds and wealth [3].
• Conducting enhanced monitoring of transactions [6].
• Searching for the customer's name on sanctions lists and in adverse media [6].
• Identifying the beneficial owners of the customer [2].

Transaction Monitoring

We monitor customer transactions for suspicious activity [6]. Suspicious activity may include transactions that are unusual in size, frequency, or pattern, or that have no apparent business purpose [2].

Reporting Suspicious Activity

We are required to report suspicious activity to the appropriate authorities [1]. Reports are filed when we know, suspect, or have reason to suspect that a transaction involves money laundering, terrorist financing, or other illegal activities [1].

Record Keeping

We maintain records of all data and documents obtained for the implementation of the AML system and KYC process [1]. These records are kept for as long as required by applicable laws and regulations [1].

Training

We provide training to all relevant employees to ensure they are aware of this AML/KYC Policy and their responsibilities in preventing money laundering and terrorist financing [1].

Policy Updates

This AML/KYC Policy will be reviewed and updated periodically to ensure its effectiveness and compliance with applicable laws and regulations [1].

Contact Us

If you have any questions or concerns about this AML/KYC Policy, please contact us.