AML & KYC Policy
The “Company”, “EXEX” does not enter into business relationships with criminals and/or terrorists and/or other illegal structures, does not transfer assets which result from criminal and/or terrorist and/or other illegal activity and does not facilitate any transfer of assets involving criminal and/or terrorist and/or other illegal activity. The Company reserves the right to implement any policies and procedures necessary to prevent all types of illegal activity and to comply with all applicable legislation in this regard.
- 1.1.The Company Anti-Illegal Activity Policy (hereinafter - the “Policy”) is designated to prevent and mitigate possible risks of EXEX being involved in any kind of illegal activity.
- 1.2.Both international and local regulations require EXEX to implement effective internal procedures and mechanisms to prevent illegal transfer of assets, drug, human, organ and any other illegal trafficking, poaching, pornography, trade in arms, terrorism and crime financing, corruption and bribery, money laundering, and to take action in case of any form of suspicious activity from its Users (the“User”).
- 1.3.The Policy covers the following matters:
- 1.3.1.Verification procedures.
- 1.3.2.Compliance Officer.
- 1.3.3.Monitoring trade activity of assets.
- 1.3.4.Risk Assessment.
- 1.3.5.KYC Policy
- 2.1.One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, EXEX establishes its own verification procedures within the standards of “Know Your Customer” frameworks.
- 2.2.EXEX’s identity verification procedure requires the User to provide EXEX with reliable, independent source documents, data or information. For such purposes, EXEX reserves the right to collect the User’s identification information for the purposes of the Policy.
- 2.3.EXEX will take steps to confirm the authenticity of documents and information provided by the User. All legal methods for double-checking identification information will be used and EXEX reserves the right to investigate certain Users who have been determined to be risky or suspicious.
- 2.4.EXEX reserves the right to verify the User’s identity on an ongoing basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular User). The Company can identify an activity as suspicious on its sole discretion.
- 2.5.EXEX reserves the right to request up-to-date documents from the User, even though they have passed identity verification in the past.
- 2.7.Once the User’s identity has been verified, EXEX considers itself being removed and legally not liable in a situation where its Services are used to conduct illegal activity.
- 3.1.The Compliance Officer is the person, duly authorised by EXEX, whose duty it is to ensure the effective implementation and enforcement of the Policy.
- 3.2.It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including but not limited to:
- 3.2.1.Collecting Users’ identification information;
- 3.2.2.Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations;
- 3.2.3.Monitoring the transfer of assets and investigating any significant deviations from normal transfer activity;
- 3.2.4.Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- 3.2.5.Updating risk assessment regularly.
- 3.3.The Compliance Officer is entitled to interact with competent authorities involved in the prevention of all types of illegal activity.
4.Monitoring of Asset Transfer
- 4.1.Users can be known not only by verifying their identity (who they are) but, more importantly, by analysing their asset transfer patterns (what they do). Therefore, EXEX relies on data analysis as a risk-assessment and suspicion detection tool. EXEX may perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.
- 4.2.Monitoring system functionalities may include:
- 4.2.1.Aggregating transfers of assets by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable.
- 4.2.2.Case and document management
- 4.3.With regard to the Policy, EXEX will monitor all transfers of assets and it reserves the right to:
- 4.3.1.Ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer;
- 4.3.2.Request the User to provide any additional information and documents in case of suspicious transfers of assets;
- 4.3.3.Suspend or terminate the User’s Account when EXEX has a reasonable suspicion that such User engaged in illegal activity.
- 4.4.The above list is not exhaustive and the Compliance Officer will monitor the User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
- 5.1.The Company, in line with the international requirements, has adopted a risk-based approach to identify and combat illegal activity. By adopting a risk-based approach, EXEX is able to ensure that measures to prevent an illegal activity are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
Having regard for the safety of the Users and due to the legal requirements of the Seychelles, the European Union, the United States of America and other countries. EXEX has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating moneylaundering and terrorist financing) as it is required by banks and other financial institutions.
The purpose of those policies is an effective combating of moneylaundering and terrorist financing (AML / CTF) on our exchange by proper identification of actual Users of our accounts and supervision of their transactions. We shall identify and cease transactions made not only to purchase / sell cryptocurrency, but made mainly to hide criminal origin of money, finance illegal activity or other unlawful behaviours.
Specific provisions of our Policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent Users. We would like to introduce you to some of general rules and stipulations of our Policies which directly concern you and affect the services we render.
- 6.1.User’s identification
In the first place we are obliged to identify, beyond a reasonable doubt, the identity of personsenabled to do transactions on our exchange. This is the reason why we collect ID scans, which authenticity is verified with special software by professional external providers.
We require you to send a “selfie” or your own recording along with your ID document in order to preclude the possibility of your documents being used by someone else. Verification of your likeness to the photo from your ID is made with the use of special software by professional external providers or, in case of doubt, done manually by our customer support services.
In case of any doubt our customer support team will contact you to explain any concernsand solve the issues that arise.
If we cannot determine, beyond a reasonable doubt, that the documents you providedbelong to you and are authentic we won’t be able to let you execute any transactions.
- 6.2.User’s identification — Companies
In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who the owner of the company is, who can represent it, where the company is based and what the business of the company is. Since standards regarding governmental documentation of legal entities is different in each country, the verification of such Users is done “manually” every time and is considerably more time consuming.
MONITORING AND SUPERVISION OF TRANSACTIONS
Using our proprietary software we also analyse all transactions that take place on our exchange looking for suspicious and unusual behaviours. Such selected transactions are analysed by our AML specialists and evaluated to check that they do not provide significant AML / CTF risks or if they need to be ceased and clarified with the User.
When your trade volume rises, our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your identity results in qualifying you as a person imposing significant AML / CTF risk. In such cases we can require additional documentation proving your real, exact place of residence, education, occupation, as well as the source of the money you are using on the exchange. Unfortunately, if our AML specialists decide that the information received from you doesnot clarify our doubts, we will be obliged to end our cooperation with you or even report your transactions to the relevant authorities.
BASIC AML / CTF RULES
- Our operating rules include inter alia as follows:
- 1.EXEX does not accept cash deposits or cash withdrawals in any cases.
- 2.EXEX does not accept any third parties’ deposits on the User's account, managing the account on behalf of somebody, joint or shared accounts, etc.
- 3.EXEX does not allow any exceptions in the field of documentation required from Users.
- 4.EXEX reserves the right to refuse to process the User’s transaction at any time, in case of suspicion of AML / CTF risk.
- 5.In accordance with international law we are not obliged (or are even forbidden) to inform our clients, if we report their behaviour as suspicious to the relevant authorities.
In accordance with our Policies we do not open accounts and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by the European Commission) impose high AML / CTF risk.
Currently these countries are: Afghanistan, Angola, Azerbaijan, Bahamas, Botswana, Burundi, Cambodia, Cameroon, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea-Bissau, Haiti, Iran, Iraq, Libya, Madagascar, Mozambique, Burma, Nicaragua, North Korea, Pakistan, Panama, Rwanda, Sierra Leone, Somalia, South Sudan, USA (some states), Sri Lanka, Sudan, Syria, Tajikistan, Trinidad and Tobago, Tunisia, Turkmenistan, Uzbekistan, Venezuela, Yemen, Zimbabwe, American Samoa, Guam, Nigeria, Puerto Rico, Samoa, Saudi Arabia, US Virgin Islands.
When your trade volume rises, AML / CTF risk increases as well. That is why we have to introduce proper safety and verification duties. Currently our KYC / AML verification model is:
You should remember that this model is a result of the work and experience of our AML team and can be changed as legal requirements of countries change as well as a result of gaining new knowledge and experience.