Anti Money Laundering / Know Your Customer (AML/KYC) Policy
The Company protects itself from involvement in money laundering or suspicious activity by the following:
- Establishing detailed AML policies and procedures.
- Performing know your customer (“KYC”) procedures on all users
- Designating a Compliance Team with full responsibility to follow AML policies strictly.
- Conducting an AML audit on regular basis.
Policies and Procedures
The Policy will be approved by the Company’s Board. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.
AML Compliance Team
The Company has a Compliance Team responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Team has a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Team is responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company’s Board.
It is the Company’s policy to ensure that it has reasonably identified each customer who uses the Company’s virtual currency trading platform. Users should be identified using a variety of methods.
Account Opening Procedures.
The Company require users to provide proof of identification; and will not permit any trades to be made by un-verified users.
Proof of Identification:
Valid ID Document, issued by Country of Residence, where is visible:
- Date and place of birth
- Date of issuance
- Expiry Date
- Number of document (serial number)
- Photo of the Individual (not valid only for very old, but still valid documents)
Additional information required:
- Email Address
- Contact Phone number
- Residence address and mailing address if different (PO Box address will not be acceptable).
- Proof of address (e.g., Utility Bill, Telephone Bill, Bank Statement, Credit card statement etc.)
Users will have option to load the document electronically from their account or send it by mail. Documents used for opening an account will be verified prior to starting trading activity. Verification of identity will require multi-factor authentication to ensure a meaningful user identity confirmation process based on account size or other factors.
The following are examples of verification methods the Company may use:
- Obtaining proof of address, such as a copy of a utility bill, Telephone bill or bank statement from the account holder.
- Having a telephone call to the number given in account opening form.
- Comparing the identifying information with information available from a trusted public source.
- Photo ID of the users.
When the type of account increases the risk for the Company or any suspicious activity is detected, the account will be closed as per Compliance Manager discretion.
SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS
The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Team will determine whether a filing with any law enforcement authority is necessary.
Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as result of the transaction.
The Compliance Team will initially make the decision of whether a transaction is potentially suspicious. Once the Compliance Team has finished his review of the transaction details, it will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.
Reasonable procedures for maintaining records of the information used to verify a person’s name; address and other identifying information are required under this Policy. The following are required steps in the record keeping process:
- The Company will maintain a record of identifying information provided by the customer.
- The Company will record the methods and result of any additional measures undertaken to verify the identity of the customer.
- All transaction and identification records will be maintained for a minimum period of five years.
- By providing all necessary documents for identification, Customers explicitly agree that their personal data will be used for purposes of identification and kept in Company records for five years.
The Compliance Team is responsible for directing the regular AML audit of the Company’s operations. The Compliance Team will provide the audit report and all corrective action plans to the Company’s senior management for review.