【Updated and Effective Date: May 1st, 2023】
Virtual Assets (VAs) and Fiat transactions
Our comprehensive set of policies and procedures have been diligently constructed to ensure secure, transparent, and regulated operations concerning Virtual Assets (VAs) and Fiat transactions. These measures aim to safeguard our platform, our clients, and the wider financial system from potential financial crimes and illicit activities.
Adherence to Regulatory Standards
We firmly uphold our regulatory obligations and work diligently to ensure our policies and procedures are in full alignment with relevant legal requirements. This commitment underpins every facet of our platform, from transaction handling to data protection, and forms a fundamental pillar of our operations. Regular reviews and audits are conducted to confirm the ongoing relevance and effectiveness of our procedures in light of changing regulatory landscapes.
Unyielding Commitment to Fiat Transaction Security
In the realm of Fiat transactions, we strive to foster an environment of uncompromising safety and transparency. To that end, we only permit fiat transfers that are processed through licensed banks or certified payment service providers. This practice, coupled with our policy of not supporting physical cash transactions, ensures a secure, auditable transactional framework that effectively curbs potential financial malpractices.
Monitoring and Control over Fiat Transfers
To maintain rigorous oversight over Fiat transactions, we enforce robust policies that enable us to execute, reject, or suspend Fiat transfers based on set criteria. Furthermore, continuous monitoring mechanisms are in place that tracks every Fiat transaction in real-time, recognizes unusual patterns, and immediately triggers an investigation into suspicious activities. Such vigilant surveillance guarantees timely detection and resolution of potential risks, ensuring enhanced user security.
Resolute Stance against Third-Party Transfers
Upholding the principle of financial accountability, we strictly prohibit third-party Fiat or VA transfers. This includes any form of transactions with non-users, inter-user transfers, and movements involving third-party external wallets. This practice ensures that our clients' assets remain within the secure confines of our platform, reducing exposure to potential external threats.
Vigilance Against Illicit Activities
Recognizing the increasing sophistication of financial crime, we have implemented stringent measures to ensure no transactions involving illicit sources take place. Our platforms are regularly scanned for suspicious activities, backed by advanced blockchain analytics software. This technology helps identify any illicit VA funds being sent or received and triggers an immediate response.
Risk-Based Approach to Monitoring Transactions
Our system employs a risk-based approach for monitoring transactions with potential illicit entities. High-risk activities, such as transactions involving blacklisted addresses, sudden spikes in transaction volumes, unusual frequency or rapid movement of funds, are immediately flagged and subjected to thorough scrutiny. Depending on the severity of the case, necessary actions are taken, ranging from enhanced due diligence to reporting the case to relevant authorities.
Prohibition of Anonymous VA Transactions
We are committed to maintaining a high level of transparency in all our operations. Consequently, we do not support transactions involving any anonymous VAs or privacy coins currently available in the market. This policy minimizes the risk of potential misuse of our platform for illicit purposes and ensures we maintain a transparent, traceable VA transaction environment.
Information Sharing for Travel Rule Compliance
In line with our regulatory obligations, we have established processes to request and respond to information requests from other entities or authorities in a timely manner. This practice ensures we comply with the Travel Rule requirements and enhances the transparency and traceability of transactions across different platforms.
In conclusion, our meticulously designed policies and procedures reflect our commitment to providing a safe, compliant, and reliable platform for our users. We continually update these measures in response to advancements in technology and regulatory changes, ensuring our platform remains a secure and trusted place for our clients to perform their VA and Fiat transactions.
Approach to VA Risk Assessment
Our risk assessment procedures are holistic and are focused on determining the potential risks associated with each VA before it gets listed or traded on our platform. The evaluation is not confined to the aspects specified in the questions; instead, we consider several other relevant factors. Our commitment to maintaining a safe and secure trading environment prompts us to go beyond the traditional risk assessment parameters.
Sanctions and Adverse Media Screening
We maintain a vigilant stance against any involvement with entities on global sanction lists. Therefore, we conduct a comprehensive sanction screening on all VA issuers before the token gets traded or listed on our platform. Simultaneously, our procedures also include Adverse Media or Negative News screening, which helps us stay informed about any negative publicity or illicit activities associated with the issuers. This dual screening process is a crucial part of our preventive strategy against potential legal and reputation risks.
Evaluating Anonymity and Legal Compliance
Our assessment process also involves evaluating the potential for anonymity that a token may offer. Any feature promoting anonymity or undermining our ability to effectively implement AML/CFT measures is treated with utmost caution. Additionally, we thoroughly examine the legal characteristics of the token to ensure they align with local laws and regulations. This also includes a careful analysis of the token's potential for use in illicit or fraudulent activities.
Monitoring Market Manipulation Risks
Tokens are susceptible to market manipulation due to their inherent volatility and liquidity characteristics. Our team monitors these factors closely to prevent potential risks. For example, we evaluate if the concentration of tokens in specific addresses might render them susceptible to fraud and market manipulation. We are constantly refining our approach to these assessments to ensure a secure trading environment.
Due Diligence on VA Issuers
We recognize that a thorough due diligence process is crucial to ensure the credibility of the VA issuers. Consequently, we conduct a rigorous CDD or ECDD process, as applicable, on all issuers before any token is traded or listed on our platform. This process includes the identification and verification of the identity of the beneficial owners of the VA issuers.
Ongoing Monitoring and Review
Our responsibility doesn't end once a token is listed on our platform. We conduct ongoing monitoring of the VA/digital token issuers to ensure they remain compliant. This includes regular reviews of their operations, legal status, and market behaviors. The results of this ongoing monitoring feed back into our risk assessments, ensuring they remain accurate and up-to-date.
Our VA risk assessment policies and procedures apply across all levels of our organization. Our entity's senior management and all staff members are well-aware of these procedures and are committed to their effective implementation.