AML Policy (anti-money laundering policy)

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Date of entry into force: 22-12-2018.
Updated on: December 22, 2024.
This AML Policy (hereinafter referred to as the Policy) regulates the activities of Fastexer in the fight against money laundering and its involvement in the fight against money laundering and the financing of terrorist activities.

Money Exchanger AML Policy

1. Introduction

  • Purpose: To establish procedures and controls to prevent money laundering, terrorist financing, and other illegal activities.

  • Scope: Applies to all employees, contractors, and business operations of the money exchange service.

  • Compliance: Adherence to local and international AML laws and regulations, such as the Financial Action Task Force (FATF) recommendations, the USA PATRIOT Act, EU AML Directives, or other relevant legislation.

2. Risk Assessment

  • Conduct regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks.

  • Evaluate risks based on customer profiles, transaction types, geographic locations, and delivery channels.

3. Customer Due Diligence (CDD)

  • Identification: Verify the identity of customers using government-issued identification (e.g., passport, driver’s license, national ID).

  • Enhanced Due Diligence (EDD): Apply additional scrutiny to high-risk customers, such as politically exposed persons (PEPs) or those from high-risk jurisdictions.

  • Record Keeping: Maintain records of customer identification and transaction details for at least five years (or as required by local regulations).

4. Transaction Monitoring

  • Implement systems to monitor and flag suspicious transactions, such as:

    • Large or unusual transactions.

    • Frequent transactions just below reporting thresholds.

    • Transactions involving high-risk countries.

  • Regularly review and update monitoring systems to address emerging risks.

5. Reporting Obligations

  • Suspicious Activity Reports (SARs): Report any suspicious transactions to the relevant financial intelligence unit (FIU) or regulatory authority.

  • Currency Transaction Reports (CTRs): File reports for transactions exceeding the regulatory threshold (e.g., $10,000 in the U.S.).

  • Ensure timely and accurate reporting in compliance with local laws.

6. Employee Training

  • Provide regular AML training to employees to ensure they understand:

    • AML laws and regulations.

    • Red flags for suspicious activity.

    • Internal AML procedures and reporting requirements.

  • Maintain records of training sessions and employee participation.

7. Internal Controls and Audits

  • Establish internal controls to ensure compliance with AML policies, including:

    • Segregation of duties.

    • Regular internal audits.

    • Independent reviews of AML procedures.

  • Address any deficiencies identified during audits promptly.

8. Sanctions Screening

  • Screen customers and transactions against global sanctions lists (e.g., OFAC, UN, EU) to prevent dealings with sanctioned individuals, entities, or countries.

9. Record Retention

  • Retain all AML-related records, including customer identification, transaction records, and reports, for the minimum period required by law.

10. Management Responsibility

  • Appoint a designated AML Compliance Officer (AMLCO) to oversee the implementation and enforcement of the AML policy.

  • Ensure senior management is actively involved in AML compliance and provides adequate resources for the program.

11. Policy Review and Updates

  • Regularly review and update the AML policy to reflect changes in regulations, emerging risks, and business operations.

  • Communicate updates to all relevant staff.

12. Zero Tolerance for Non-Compliance

  • Enforce strict disciplinary actions for employees who fail to comply with the AML policy.

  • Terminate relationships with customers or partners involved in money laundering or terrorist financing.

Conclusion

This AML policy is designed to ensure that the money exchange business operates in compliance with all applicable laws and regulations while protecting the organization from being used for illegal activities. All employees must adhere to this policy, and any breaches will be dealt with seriously.

This is a general template and should be customized to meet the specific legal and operational requirements of your jurisdiction and business. Consult with legal and compliance experts to ensure full compliance with local and international AML regulations.

 KYT Policy

(Know Your Transaction)

Date of entry into force: 01.10.2022.
Updated on June 22, 2023.
The KYT (Know Your Transaction) policy aims to identify the client of a transaction in the event of a use case where the Service has reasonable suspicion that the Client is using Fasexer for other purposes.

Such a precedent may arise if the Service suspects the Client of illegal actions that can be qualified as laundering or attempted laundering of illegally obtained digital assets or if the funds are of overtly criminal origin. For these purposes, the Service has the right to use any legal information, and third-party tools for analyzing the origin of digital assets, as well as its developments in the screening system. Any content of high-risk assets as a result of the verification may cause suspicion.

In this case, the Fastexer Service reserves the full right to:

    1. Require the Client to provide additional information disclosing the origin of digital assets and/or confirmation that these assets were not obtained by criminal means;
    2. To block the account and any operations related to the Client, to transfer to the controlling financial activities and/or law enforcement agencies at the place of registration of the Service and, if necessary, at the address of the Client’s registration, all information and documents available on the incident;
    3. Require from the Client documents confirming identity, physical existence, address of registration, and solvency;
    4. To return digital assets only to the details from which the transfer was made or switch to other details, after a full check by the Service’s security service, if it was possible to verify the legal origin of the Client’s funds;
    5. Refuse the Client to withdraw funds to the account of third parties without explanation;
    6. Hold the Client’s funds until the incident is fully investigated;
    7. The Service reserves the right to monitor the entire chain of transactions to identify suspicious transactions;
    8. The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to withhold funds on special accounts of the Service;
    9. The Service reserves the right to refuse to provide the Service to the Client if the Service has reasonable suspicions of the legitimacy of the origin of digital assets and to hold funds on special accounts of the Service if it is impossible to track the entire chain of movement of digital assets from the moment they appear.

    Conditions for making a refund of funds stopped for verification based on the results of the AML analysis of the transaction:

    Refunds are made after a full check by the Service’s security service, which may include detailed verification of the sender. Refunds are made minus a commission of up to 5% of the transaction amount to cover the labor costs for processing the application and arranging a refund.
    The return, subject to approval by the Service, will be processed by the Service within 7 (seven) calendar days, starting from the date when the User was notified of the Service's decision regarding his return request.
    When making a refund, after passing the check (verification), the user must confirm the details to receive a refund.

DISCLAIMER (WebMoney)

Offered goods and services are provided not at the order of an individual or enterprise operating the WebMoney Transfer System. We are an independent enterprise providing services and making independent decisions about pricing and offers. Enterprises, operating the WebMoney Transfer System, do not receive any fees or other remuneration for participation in the provision of services and do not bear any responsibility for our activity.

Accreditation performed by WebMoney Transfer exclusively to confirm our contact details and verify the identity. It is performed at our will and does not mean that we in any way are connected with the sales conducted by the WebMoney System operators.

Communication with the AML Compliance Officer regarding this Policy is conducted via [email protected].