Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

1. INTRODUCTION

The purpose of our AML/CTF Policy is to prevent money laundering and terrorist financing activities at CoinifyNex. This summary provides an overview of our key principles. For more details, please contact our customer support.

CoinifyNex complies with both domestic and international regulations to establish effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug trafficking, human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery. We are committed to acting on any suspicious activities conducted by our customers.

2. General Principles

CoinifyNex implements several procedures to ensure compliance with AML and CTF regulations, including:

  • We confirm the identity of all customers through reliable documents, ensuring they are genuine individuals or legal entities. This includes valid government-issued identification for individuals and registration documents for corporate clients.
  • We keep detailed records of all transactions and customer information to ensure transparency and traceability.
  • We continuously monitor transactions for any unusual or suspicious activity that may indicate money laundering or terrorist financing.
  • We ensure all relevant employees are trained on their AML responsibilities and the company's procedures, enabling them to detect and report suspicious activities effectively.

3. Identity Verification

When verifying the identity of a new customer, we ensure that the documents provided adequately prove the existence of the customer as a genuine individual or legal entity. This process includes:

  • Customers must providevalid government-issued identification, such as a passport or ID card.
  • For corporate clients, we require registration documents, details of beneficial ownership, and identities of individuals with control over the account.
  • The collection, storage, sharing, and protection of customer identification information strictly adhere to our Privacy Policy and comply with GDPR requirements.

4. Anti-Money Laundering Compliance Officer (AMLCO)

The AMLCO at CoinifyNex is responsible for ensuring compliance with AML regulations. The AMLCO has the necessary authority and access to pertinent information required to fulfill their duties effectively. Responsibilities include:

  • Ensuring all AML/CTF policies and procedures are followed.
  • Providing comprehensive training to employees on AML responsibilities.
  • Forwarding and reporting all suspicions of money laundering to the appropriate authority. To contact our AMLCO, email us at: support@coinifynex.com.

5. Monitoring of Transactions

Continuous monitoring of customer accounts and transactions plays a crucial role in managing the risk of money laundering and terrorist financing. Our procedures include:

  • Regularly reviewing transactions to identify any that deviate from the customer's established behavior or risk profile.
  • Monitoring large transactions, rapid movement of funds, use of privacy-enhancing cryptocurrencies, geographic risks, and mixing services.
  • Promptly investigating and reporting any suspicious activities to the Financial Analytical Unit (FAU) of the Czech Republic.

6. Risk Assessment

CoinifyNex adopts a risk-based approach to identify and manage money laundering and terrorist financing risks. This approach includes:

  • Understanding that the threat of money laundering or terrorist financing varies among customers, countries, services, and financial instruments.
  • Tailoring our policies, procedures, and controls to address specific business risks.
  • Focusing resources on areas with higher risks to enhance the effectiveness of our AML/CTF measures.
  • The AMLCO continuously monitors and assesses the effectiveness of the measures and procedures outlined in this policy.

7. Sanctions

CoinifyNex strictly adheres to international sanctions, prohibiting transactions with individuals, companies, or countries subject to these measures. Our sanctions compliance includes:

  • Using robust systems and processes to screen against relevant sanction lists and watchlists.
  • Ceasing transactions and reporting incidents to the appropriate regulatory authorities if any customer, counterparty, or transaction is found to be in violation of international sanctions.

8. Prohibited Countries

CoinifyNex does not provide services to individuals residing in certain countries associated with high money laundering risks. The list of prohibited countries is determined based on various factors, including assessments by international anti-money laundering organizations. The list is regularly updated and detailed in our full AML Policy, available upon request. By restricting services to these countries, we aim to mitigate potential risks and ensure compliance with applicable laws and regulations.

9. Enhanced Due Diligence (EDD)

For high-risk transactions, CoinifyNex implements Enhanced Due Diligence (EDD) procedures to provide a deeper understanding of high-risk customers and their transaction behaviors. EDD includes:

  • Investigating the customer's background, source of funds, and purpose of transactions.
  • Applying heightened ongoing monitoring to detect deviations from expected transaction patterns.
  • Maintaining detailed records of the EDD process and reporting any suspicious activities to relevant authorities.

10. Compliance Monitoring and Internal Controls

CoinifyNex has established a robust system of compliance monitoring and internal controls to ensure adherence to AML/CTF regulations. This includes:

  • A dedicated Compliance Officer oversees the implementation and effectiveness of the AML/CTF program.
  • Conducting internal and external audits to assess the effectiveness of our AML/CTF program.
  • Employing advanced technological tools for efficient transaction monitoring and screening against sanction lists.
  • Providing regular training to all employees on AML/CTF regulations, identification of suspicious activities, and reporting procedures.

11. Penalties for Non-Compliance

CoinifyNex has established clear consequences for non-compliance with AML/CTF regulations, including:

  • Formal warnings, mandatory re-training, suspension, termination, and potential legal action for severe violations.
  • Regulatory sanctions, fines, business restrictions, and potential revocation of licenses.

12. Policy Review and Updates

CoinifyNex is committed to maintaining an AML/CTF policy that adapts to changes in regulations and emerging risks. Our review and revision process includes:

  • Conducting scheduled reviews of the AML/CTF policy and procedures at least annually.
  • Involving key stakeholders in the review process to gather insights and feedback.
  • Monitoring updates from regulatory bodies and incorporating changes into our policies.
  • Re-evaluating our risk assessment framework to ensure it reflects the current risk landscape.
  • Documenting all reviews and revisions for regulatory examination and internal auditing purposes.

13. Contacts

For any questions or concerns about our AML Policy, or to report suspicious activities, please contact our AMLCO department via email at support@coinifynex.com. Your vigilance helps us maintain a secure and compliant environment. We value your trust and remain committed to upholding the highest standards of compliance and anti-money laundering practices.

stars