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AML/KYC Policy

1. Introduction

1.1 This AML/KYC Policy ("Policy") outlines the guidelines, principles, and procedures that XCoinPulse Ltd and its affiliates ("Company") adhere to in order to detect and prevent financial crimes, including money laundering and terrorist financing, in compliance with all relevant and applicable laws.

1.2 This Policy is part of the Company's Terms of Service, which are always available on the Company's Website. The Policy details the primary principles and rules for identifying and preventing financial crimes, including money laundering and terrorist financing, in compliance with all relevant laws.

1.3 The Company is committed to preventing its services from being used for money laundering, terrorism financing, or any other illicit activities.

1.4 The Company has implemented internal procedures ("Procedures") developed in accordance with UK laws and regulations. These Procedures are managed by the Company's Compliance Department, led by the AML Officer (MLRO) and their team, in strict compliance with the applicable laws.

1.5 The Compliance Department ensures adherence to AML/KYC regulations and oversees the implementation of the Procedures within the Company.

2. Services and AML/KYC Principles

2.1 In accordance with UK law and AML/CFT regulations, the Company provides licensed virtual asset services as specified in the Terms of Service.

2.2 The Company applies AML/KYC principles, rules, measures, and procedures in strict compliance with AML/CFT regulations to detect and prevent financial crimes, including money laundering and terrorist financing.

3. Protective Measures

3.1 The Company has developed protective measures to prevent involvement in suspicious financial activities. These measures include:

  • Conducting AML/KYC checks on Users (both individuals and entities) and their representatives;
  • Performing risk assessments to determine the Company's risk profile;
  • Implementing internal policies and controls to mitigate risks of financial crimes;
  • Providing AML/CFT training to employees;
  • Conducting regular AML/CFT audits (internal and external);
  • Maintaining and updating User data and documentation;
  • Reporting suspicious transactions to relevant authorities in compliance with AML/CFT regulations;
  • Taking all necessary steps to detect and prevent financial crimes in accordance with the law.

4. AML/KYC Measures

4.1 As part of User Due Diligence, the Compliance Department:

  • Identifies and verifies User information through reliable and independent sources, including e-identification methods;
  • Investigates Users flagged as high-risk or suspicious;
  • Requests additional or updated information as necessary;
  • Confirms the authenticity of User data and documentation;
  • Monitors User transactions on an ongoing basis.

4.2 The Company reserves the right to request additional information from any User at any time, even if they have been previously verified.

4.3 The Company may suspend services to Users or report them to authorities if they fail to provide requested information in compliance with the law.

5. Verification Levels and Required Information

5.1 The Company implements various AML/KYC verification levels to detect and prevent financial crimes.

5.2 Verification levels affect the extent of activities a User can perform on the Company's platform. The terms include:

  • Valid ID:
    • a) Identity card or digital identity card;
    • b) Driving license;
    • c) Residence permit;
  • Proof of Residence: Bank statement, utility bill, insurance document, credit card statement, or tax statement issued within the last three months.

5.3 In compliance with AML/CFT laws and internal policies, Users may need to provide Proof of Funds for transactions to verify the lawful source of their funds.

5.4 Users may also be required to complete an AML/KYC Questionnaire, which may include questions or a video call with the Compliance Department to assess the intent and source of funds for their transactions.

6. Risk Assessment Principles

6.1 The Company considers various risk factors during initial and ongoing risk assessments, including User and geographical risks.

6.2 Risk assessments consider discrepancies in ID documents, fictitious identities, stolen identities, previous financial crime records, and other suspicious factors.

6.3 The Company pays special attention to high-volume and unusual transactions, or linked transactions, performed by Users.

6.4 Based on risk assessments, the Company may apply simplified or enhanced AML/KYC measures as required by AML/CFT laws.

6.5 The Company maintains a list of high-risk countries, based on EU and FATF lists, to assess the risk associated with Users, transactions, and business relationships.

7. Monitoring Requirements

7.1 The Company continuously monitors activities to prevent financial crimes. Monitoring activities include:

  • Reviewing User transactions;
  • Requesting updates or confirmations of User data as needed;
  • Verifying the lawfulness of the User’s source of funds;
  • Paying special attention to suspicious, high-volume, and unusual transactions;
  • Focusing on transactions from high-risk countries;
  • Implementing other monitoring measures in compliance with AML/CFT regulations.

8. Reporting Suspicious Activities

8.1 If the Company suspects a suspicious transaction, it will conduct further inquiries using the AML/KYC Questionnaire and request additional information as needed.

8.2 If a User fails to provide requested information or provides suspicious information, the Company may suspect that the User’s activities are related to financial crimes. In such cases, the Company will report the suspicious activities to the relevant authority and may suspend the User’s account.

9. Contacting Compliance Department

9.1 For questions about this AML/KYC Policy or related procedures, or to file a complaint, contact the Compliance Department at compliance@xcoinpulse.com.