AML & CTF Compliance Policy Declarations
Accordingly, we have taken the necessary procedures and control measures to provide the perfect support against the fight of money laundering and financial terrorism.
To ensure the continuity of high standards of AML Compliance, our internal audit regime monitors, and tests the Compliance Program through random examination of the relevant processes, accordingly, the findings are documented and reported to the board of directors.
Crypdom Exchange LLC is subject to local regulations, which are fully compliant with the international requirements of the FATF, and Dubai Financial Services Authority.
Our policy includes:
• Exercise a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
• Maintaining risk based systems and procedures to monitor on-going customer activity on daily basis
• Procedures for reporting suspicious or unusual activity, internally and to the relevant law enforcement authorities as appropriate;
• The maintenance of appropriate records for the minimum prescribed periods;
• Training and awareness for all the employees
Ascertainment of Customer Identity
The customer’s identity is verified and screened against international blacklists and sanctions lists before accepting every transaction in every currency regardless of the amount.
‘Know Your Customer/Customer Due Diligence procedures and guidelines’ are scrupulously adhered to.
Establishment of Beneficial Ownership of Funds
In the case of multiple transactions on daily, weekly or monthly basis, the customer is mandated to furnish a valid proof of source of funds and also the supporting document(s) to substantiate the purpose of a transaction which may vary on a case to case basis.
Enhanced Know Your Customer/Due Diligence
Enhanced due diligence is conducted when transactions appear to be potentially suspicious on the basis of well-defined red flag indicators. Our client relationship staff ensures to seek additional identification documents or documentary proof of source of the fund as deemed appropriate by the Compliance regime.
In such cases, an in-depth due diligence is conducted outlining the transaction behavior, and the regular surveillance of remittances that may reveal potentially suspicious activities.
On an daily basis, our platform enables us to analyze the transaction behavior of the users while monitoring the volumes and frequency of their transactions.
In addition to the above, our tools enable us to identify the red flags based on different parameters we use for risk profiling of our customer base such as:
• Expected transaction volumes and frequency
Internal Reporting of Unusual/Potentially Suspicious Transactions
All client relationship staff liaising with the client(s) for increased limits requests and overseeing subsequent remittances in the client’s account is required to report any potentially suspicious or unusual transactions to our Compliance Officer using our internal reporting system.
Reporting of Unusual/Suspicious Transactions
All Staff is required to detect and report unusual/potentially suspicious transactions to Compliance Officer who will, in turn, conduct an in-depth investigation, and take an appropriate action before documenting such transactions or activities in the form of UARs and SARs respectively and file them for the auditors and prospective regulator(s).
Every employee is trained on AML-CFT procedures with follow-up training scheduled yearly and in the case of significant amendments to the policies, whichever occurs first.
All records including customers’ identification documents, transaction data, and any other related documents are retained as long as they hold an account with Crypdom Exchange and subsequently for a minimum period of five years after the closure/redundancy of the account.
Confidentiality of Records and Suspicious Transactions
All customer records and transactional information is kept confidential at all times, and the customers are not intimated if their transactions are considered suspicious and being reported to Compliance Officer internally, or are being filed as UARs or SARs. Non-Compliance of the aforementioned invites criminal charges against Crypdom Exchange, its Directors, Management, and its employees at fault.
Internal Audit’s Role
Internal Audit tests the effectiveness of the Compliance Regime and performs random checks on its key responsibilities. All findings and observations are discussed with the Compliance Officer and are reported to the board of directors.