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Anti-Money Laundering Policy

What is Money Laundering?

Money laundering is a process intended to mask the benefits derived from a predicate criminal activity so that funds appear to have originated from a legitimate source. These funds often enter the financial system through institutions such as banks, fund houses, trust companies and corporate service providers.

Generally, the process of money laundering comprises of three stages, during which there may be numerous transactions that could alert a financial institution to money laundering activity:

  1. Placement: the physical disposal of benefits derived from the predicate criminal activity;
  2. Layering: the separation of benefits derived from the predicate criminal activity from their source by creating layers of financial transactions designed to disguise the audit trail; and
  3. Integration: the provision of apparent legitimacy to benefits derived from the predicate criminal activity. If the layer process succeeds, integration schemes place the laundered funds back into the economy so that they re-enter the financial system appearing to be legitimate business.

Money laundering is a serious offence. In law, it is regarded as being almost as serious as the offence which generated the criminal process. It should be kept in mind that where an employee assists a client to place, layer or integrate illegal funds that employee may have engaged in the act of money laundering. If an employee turns a blind eye where they believe a client is involved in laundering the proceeds of crime, that employee could be charged with assisting in laundering the proceeds of crime.

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 to be responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Team will have a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Team will be responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company’s Board.

Suspicious Transaction and Activity Report 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 a 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, he or she 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.

AML Policy Audit

Licensed payment service providers are required to have in place adequate independent audit arrangements to regularly assess adequacy and the effectiveness of its procedures, controls and its compliance with regulatory requirements.

In addition, with regards to Anti-Money Laundering/Countering Financing of Terrorism controls, licensed payment service providers must maintain an audit function to assess the effectiveness of its internal policies, procedures, controls and adherence to regulatory requirements. will go for an Independent Audit to review and assess the compliance with the AML/CFT framework.

What is Travel Rule?

The Financial Action Task Force introduced the Travel Rule in June 2019 to prevent terrorists and other criminals from having unrestricted access to wire/crypto transfers for moving their funds, and to detect such misuse when it occurs. The purpose of Travel Rule is to ensure that basic information on the originator and beneficiary of wire/crypto transfers is collected and made readily available. The information collected will help AML/CFT efforts by enabling financial authorities to detect and prevent money laundering activities that involve cryptocurrencies.

Information required for Travel Rule

When you make a Buy Order on our platform, you will be required to provide us with your wallet address and the source of the wallet (private wallet - Trust Wallet/Metamask etc. OR exchange wallet – Binance/Huobi/FTX etc.). Your wallet address and wallet source, together with the Personal Information you provided during your Account Verification will be submitted to other VASP (Virtual Asset Service Providers) for us to comply with the Travel Rule requirements.

By making an order, you acknowledge and agree to allow us to provide our Travel Rule service provider with your personal information mentioned above.

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