Introduction.

The purpose of CRYPTOWITS’s Anti-Money Laundering, Counter-Terrorist Financing, and Know Your Customer Policy (hereinafter referred to as the ‘AML/CTF Policy’) is to identify, prevent, and mitigate potential risks of involving the Cryptocurrency Exchange Platform CRYPTOWITS.com (‘CRYPTOWITS’) in illegal, fraudulent, or other prohibited activities across applicable jurisdictions.

CRYPTOWITS is committed to strict compliance with Know Your Customer (KYC) and AML/CTF laws and regulations, reaffirming its dedication to avoiding willful violations of these policies. Within reasonable control, CRYPTOWITS will implement necessary measures and technologies to provide services that are inherently safe and secure, thereby maximizing protection against financial losses due to money laundering.

Our KYC and AML/CTF policies form a comprehensive framework based on international standards and the specific KYC and AML regulations applicable in relevant jurisdictions.

Through our robust compliance infrastructure, CRYPTOWITS diligently adheres to regulatory requirements and standards at both local and global levels, ensuring the continued operational integrity of our Platform by:

Fulfilling Know Your Customer (KYC) and Know Your Business (KYB) verification obligations, which include identifying the customer (natural person or legal entity), beneficial owners (if any), and understanding the nature and purpose of the business relationship.

Maintaining constant vigilance over User-initiated transactions to detect fraudulent behavior and/or criminal activity. Legislation mandates that the level of vigilance be adjusted according to the User’s or transaction’s risk profile. A Suspicious Activity Report (SAR) must be filed with the competent authorities if any User operation is suspected of criminal activity, fraudulent behavior, etc.

CRYPTOWITS has implemented effective internal procedures in accordance with international and local regulations in the various jurisdictions where it operates legally. These procedures aim to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery, and to respond appropriately to any form of criminal activity by users of the CRYPTOWITS platform (hereinafter referred to as ‘Customers’ or ‘Users’).

Money Laundering.

Money laundering, as defined by international regulations and laws aimed at combating money laundering and terrorist financing, includes the following activities:

Altering the legal status of digital assets or transferring them, with knowledge that these assets originate from criminal activity, or engaging in such activity with the intent to conceal or obscure their illicit origins. This also includes aiding individuals involved in criminal activity to evade legal consequences. Additionally, participating in or being involved in an arrangement, knowing, reasonably suspecting, or having reason to suspect that it facilitates the acquisition, retention, use, or control of criminally obtained assets.

Concealing or disguising the true nature, origin, source, location, disposition, movement, ownership, or other rights related to property, while knowing that the property is derived from criminal activity or by participating in such activity.

Acquiring, managing, or using property while knowing, at the time of acquisition or transfer, that it originates from a criminal act or by participating in such activity. It is an offense to acquire, use, or possess such criminally derived property, regardless of any attempts to conceal its criminal origins. Notably, this offense does not require active involvement in the laundering process.

Engaging in preparatory actions, attempting to commit, or being complicit in any of the activities outlined in points 1, 2, and 3 of this section is also considered an offense.

Money laundering must be criminalized separately from predicate offenses. This means that acts involving the concealment of the origins of digital assets derived from illegal activities are treated as an independent crime, requiring prosecution regardless of the initial criminal activity.

The AML/CTF Policy identifies three key stages of money laundering:

Placement: The introduction of unlawfully acquired funds into the financial system.

Layering: The process of distancing illicit funds from their source through complex financial transactions. This involves moving money through multiple accounts, financial operations, or jurisdictions to obscure its origin.

Integration: The reintroduction of laundered funds into the legal economy without any apparent link to their illegal origin, often achieved through investments or purchases that create the appearance of lawfully obtained wealth.

CRYPTOWITS MAINTAINS A STRICT ZERO-TOLERANCE POLICY TOWARDS MONEY LAUNDERING, TERRORIST FINANCING, CORRUPTION, BRIBERY, AND TAX EVASION, REGARDLESS OF ANY PREDICATE OFFENSE.

CRYPTOWITS is required to notify the designated Regulatory Authorities, as mandated by relevant international Anti-Money Laundering (AML) frameworks (such as FNTT, NCA, AUSTRAC, FINTRAC, FAU, etc.), within one working day of becoming aware or suspecting that assets, regardless of their value, have been acquired directly or indirectly from a criminal act or involvement in such activities. This obligation also applies if there is knowledge or suspicion that these assets are linked to the financing of terrorist activities, in compliance with international AML standards.

Terrorist Financing.

Terrorist financing refers to the intentional provision or collection of funds, by any means, directly or indirectly, with the aim of supporting or knowingly facilitating terrorist acts. This involves legitimate entities or individuals providing financial support to terrorist activities or organizations due to ideological, political, or other motivations.

Terrorist financing can occur when legitimate businesses or individuals choose to fund terrorist activities or organizations for ideological, political, or other reasons.

CRYPTOWITS is obligated to ensure that its Users:

• Are not designated as terrorist organizations.
• Do not facilitate the funding of terrorist organizations.

Tax evasion, Tax Fraud

Tax evasion and tax fraud involve intentional efforts to evade paying the full amount of taxes owed to the government. These offenses include deceptive actions designed to avoid tax obligations, either in full or in part. Tax fraud specifically entails deliberate deceit with identifiable material components.

Tax fraud can be constituted by:

• Voluntary omission or deliberate errors in tax declarations.
• Concealing taxable income or assets.
• Organizing insolvency to avoid tax payment.
• Using other tactics to obstruct tax collection.

Bribery and Corruption.

Bribery and corruption involve actions where an individual improperly offers, promises, or provides an undue advantage to influence someone else’s performance of their duties. This advantage, whether monetary or non-monetary, is intended to prompt the recipient to act, delay, or neglect their duties in a way that compromises honesty and integrity. Conversely, it is also considered corruption when an individual accepts or seeks such an advantage in connection with their responsibilities.

Special attention should be given to individuals at risk of engaging in corrupt practices. Specifically, those who exploit their influence for personal gain commit acts of money laundering when they deposit, use funds obtained improperly, or convert advantages gained through their positions of authority into monetary assets.

AML/CTF Regulation.

1. International Legislation Regulating the AML/CTF Policy of CRYPTOWITS:
2. International Convention for the Suppression of Terrorist Bombings – Adopted by the United Nations General Assembly on December 15, 1997.
3. United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances – Held in Vienna on December 20, 1988.
4. United Nations Convention against Transnational Organized Crime – Adopted by the United Nations General Assembly Resolution 55/25 on November 15, 2000.
5. The Basel Declaration – Approved on December 28, 1988, by the Basel Committee on Banking Regulation and Supervision.
6. Financial Action Task Force (FATF) 40 Recommendations – Established by FATF in a report on February 6, 1990, in Paris. These recommendations, last updated in February 2023, focus on preventing money laundering and countering terrorist financing.
7. Commission Delegated Regulation (EU) 2016/1675 – Adopted on July 14, 2016, supplementing Directive (EU) 2015/849 of the European Parliament and Council. It identifies high-risk third countries with strategic deficiencies.
8. Fourth Anti-Money Laundering Directive (Directive 2015/849/EU) – Enacted on May 20, 2015, aimed at preventing the misuse of the financial system for money laundering or terrorist financing. It amends Regulation (EU) No 648/2012 and repeals Directive 2005/60/EC and Commission Directive 2006/70/EC.
9. Fifth Anti-Money Laundering Directive (Directive 2018/843/EU) – Enacted on May 30, 2018, amending Directive (EU) 2015/849 on preventing the misuse of the financial system for money laundering or terrorist financing, and Directives 2009/138/EC and 2013/36/EU.

Risk-Based Approach.

CRYPTOWITS adopts a risk-based approach in its AML/CTF strategy to manage the inherent risks in its operations, utilizing a standardized risk rating model to assess money laundering exposure across User relationships. This approach is tailored to the nature, scale, and complexity of its business activities.

Through this risk-based methodology, CRYPTOWITS continually identifies and evaluates AML/CTF risks inherent in its operations. By thoroughly understanding these risks, CRYPTOWITS can pinpoint vulnerable areas within its operations and implement appropriate AML/CTF measures to effectively mitigate these risks.

When applying a risk-based approach, CRYPTOWITS will:

• Identify the money laundering risks relevant to its business activities.
• Conduct a detailed risk assessment of the business, focusing on the risk factors outlined by money laundering regulations.
• Perform risk assessments of both existing and prospective Users.
• Design and implement controls to manage and reduce the impact of actual and emerging risks.
• Monitor these controls and enhance their efficiency.
• Maintain records of actions taken, including the reasoning behind those actions.

Customer Due Diligence (CDD).

Customer Due Diligence (CDD) is essential to understanding the AML/CTF compliance procedures at CRYPTOWITS.

CDD plays a crucial role in protecting the financial services sector from being exploited for money laundering or terrorist financing. Gathering comprehensive information about Users and effectively utilizing this data is the primary defense against the laundering of illicit funds.

CRYPTOWITS is required to conduct thorough CDD and ongoing monitoring to verify User identities, identify any third-party involvement, ensure compliance with legal requirements for service provision, and cooperate with law enforcement by providing relevant information on Users or activities under investigation.

Overview of CDD measures:

User Identification and Identity Verification: This process involves gathering necessary information to confirm the User’s identity through credible and independent sources. Required details include name, address, date of birth, and official identification documents.

Beneficial Owner Identification and Verification, if applicable: When relevant, determine and verify the identity of the beneficial owner(s) who ultimately own or control the User. This step ensures clarity regarding ownership and control structures.

Understanding the Purpose and Nature of the Business Relationship: Obtain a clear understanding of the purpose, intended nature, and expected frequency of the business relationship. This includes understanding the types of transactions or activities expected within the relationship.

Ongoing Monitoring and Due Diligence: Continuously monitor User transactions and activities to identify any abnormal or unusual behavior. Establish systems to regularly observe transactions and mechanisms to investigate any irregular activities.

Risk Assessment and Risk-Based Approach: Conduct risk assessments to categorize Users based on their risk levels, considering factors such as industry, location, and transaction nature. Apply a risk-based approach to allocate resources effectively, managing higher-risk Users more closely while easing the burden on lower-risk ones.

Legal and Regulatory Compliance: Ensure that the User adheres to all relevant legal and regulatory requirements, including industry-specific regulations and anti-money laundering laws.

Enhanced Due Diligence (EDD): For higher-risk Users or transactions, implement additional checks such as requesting extra documentation, obtaining senior management approval for relationships, or conducting more frequent reviews.

Record-Keeping and Documentation: Keep detailed records of all due diligence processes, including User information, identity verification documents, risk assessments, and transaction records. This documentation is vital for regulatory compliance and audits.

Training and Awareness Programs: Provide regular training to staff involved in Customer Due Diligence (CDD) to ensure they have the knowledge and tools needed for effective due diligence. This promotes a culture of compliance and vigilance throughout the organization.

Transaction Monitoring Systems: Deploy automated Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) systems that continuously analyze transactions for abnormal or suspicious activity. These systems use algorithms to detect anomalies that may indicate money laundering.

Adverse Media Screening: Perform searches across media sources to uncover any negative information about Users or beneficial owners. This helps assess potential risks associated with the individuals or entities.

Politically Exposed Persons (PEPs) Screening: Screen Users to determine if they are Politically Exposed Persons, who hold prominent public positions. This additional scrutiny assesses associated risks and ensures appropriate due diligence measures.

Geographic Risk Assessment: Assess risks related to specific geographic locations or jurisdictions, as some regions may have weaker AML/CTF regulations or higher financial crime rates. Tailor due diligence measures accordingly.

Collaboration and Information Sharing: Collaborate with other financial institutions or authorities to exchange insights and intelligence on emerging risks or criminal activities, supporting a collective effort against financial crimes.

CRYPTOWITS often requires not only identifying the User but also understanding their business activities. This insight is crucial for assessing whether transactions and activities align with the User’s declared business, ensuring effective risk assessment and compliance measures.

Know Your Customer (KYC) and Know Your Business (KYB).

When establishing a business relationship, CRYPTOWITS must understand the expected nature of a User’s business activities to define what constitutes normal operational patterns. As the relationship develops, routine transactions by the User are compared against these expected patterns. Any deviations or unexplained activities are investigated to detect potential signs of money laundering or terrorist financing.

At the outset, personal information such as nationality, date of birth, and residential address is collected. This information is crucial for assessing the risk of financial crimes, including Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). For high-risk transactions, additional verification of the provided information may be necessary.

When the User is a legal entity (company), the Know Your Business (KYB) compliance process becomes more rigorous, depending on factors like the company’s structure, location, and other relevant details. Identifying the company’s ownership, authorized representatives, domicile, and business nature is required.

Due to differing standards for legal entity documentation across jurisdictions, the verification process for such Users involves Enhanced Due Diligence (EDD) procedures, which significantly extends the time required.

Source of Funds.

Verification of the source of funds, including payment methods, origins, and the entities involved, is crucial for CRYPTOWITS to comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. CRYPTOWITS enforces rigorous procedures to ensure thorough understanding of the source of funds at the beginning of any User relationship.

Users must provide documentation to verify the origin of their funds, such as bank statements or proof of specific transactions like inheritances or insurance payouts.

Additionally, CRYPTOWITS routinely seeks clarification on the source of funds for compliance reasons, considering the legal nature of these funds. Acceptable sources include:

• Employment Income: Wages, bonuses, dividends, and other earnings from employment.
• Retirement Benefits: Pension payments and similar retirement-related income.
• Savings and Investments: Interest from savings accounts and returns from various investments.
• Proceeds from Asset Sales: Money obtained from selling property or other assets.
• Genuine Windfalls: Legitimately won money from betting, lotteries, or similar sources.
• Inheritances and Gifts: Funds received through inheritance or as gifts.

Conversely, illegitimate sources of funds include money obtained through terrorism, fraud, bribery, or money laundering.

Prohibited activities.

CRYPTOWITS consistently updates its list of prohibited activities. The following operations are strictly forbidden:

• Drugs and Drug Paraphernalia: Includes narcotics, controlled substances, and any equipment for drug production or use.
• Marijuana/Cannabis Dispensaries: Covers businesses and products related to marijuana or cannabis.
• Weapons and Explosives: Encompasses weapons, ammunition, gunpowder, and other explosives, including fireworks.
• Toxic and Hazardous Materials: Includes toxic, flammable, and radioactive substances.
• Pseudo-Pharmaceuticals: Substances designed to mimic illegal drugs.
• Sexually Explicit Content and Services: Includes sexually explicit materials and related services.
• Pyramid and Investment Schemes: Covers pyramid schemes, multi-level marketing schemes, and other deceptive practices.
• Speculative Financial Instruments: Includes items used for speculation or hedging, such as derivatives.
• Credit and Collection Services: Includes services related to credit and debt collection.
• Intellectual Property Infringement: Items violating intellectual property rights, such as copyrights, trademarks, trade secrets, or patents, including counterfeit or unauthorized goods.
• Legally Varying Products: Products and services with differing legal statuses across jurisdictions.
• Disclosure of Personal Information: Transactions that reveal third-party personal information in violation of the law.
• Cloud-Mining Transactions: Transactions related to cloud-mining activities.
• Sanctioned Entities: Transactions involving entities under sanctions.
• Other High-Risk Activities: Any other business activities deemed outside our risk appetite at our sole discretion.

Enhanced Due Diligence (EDD).

CRYPTOWITS must implement Enhanced Due Diligence (EDD) measures on a risk-sensitive basis for any situations that inherently pose a higher risk of money laundering or terrorist financing. This means that, based on its risk-based approach, CRYPTOWITS may determine that standard identity verification is insufficient for assessing money laundering or terrorist financing risks and may require additional information about a specific User.

The level of additional information required and the extent of ongoing monitoring for any User or category of User will be based on the assessed risk of money laundering or terrorist financing.

Given the non-face-to-face nature of the business, CRYPTOWITS applies EDD to all Users. This includes monitoring all transactions, tracking IP addresses, and reviewing all crypto wallets associated with deposits and withdrawals. The EDD process is continually reviewed, and the Chief Compliance Officer (CCO) provides a quarterly report to the board to address any issues and suggest improvements.

Additional due diligence is conducted when:

Engaging with natural persons or legal entities from countries identified as high-risk.

Investigating the background and purpose of complex or unusually large transactions, as well as any unusual transaction patterns lacking apparent economic or lawful purpose.

Managing accounts with significant transactional activity.

Interacting with Users who may be Politically Exposed Persons, listed on sanctions lists, or associated with adverse media.

The monitoring of business relationships will be intensified to identify whether activities or transactions appear unusual or potentially criminal.

Politically Exposed Persons (PEP’s) Screening

To ensure that CRYPTOWITS identifies any Users who are Politically Exposed Persons (PEPs) or on sanctions lists, the company has opted to utilize independent external screening tools for all Users.

A Politically Exposed Person (PEP) is defined as a natural person who is or has been entrusted with prominent public functions, including:

(a) Heads of State, heads of government, ministers, and deputy or assistant ministers;

(b) Members of parliament or similar legislative bodies;

(c) Members of the governing bodies of political parties;

(d) Members of supreme courts, constitutional courts, or other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances;

(e) Members of courts of auditors or central bank boards;

(f) Ambassadors, chargés d’affaires, and high-ranking military officers;

(g) Members of the administrative, management, or supervisory boards of state-owned enterprises;

(h) Directors, deputy directors, and board members of international organizations.

Positions (a) to (h) exclude middle-ranking or lower-level officials.

Family members of a Politically Exposed Person include:

(a) The spouse or equivalent of a PEP;

(b) The children and their spouses or equivalents of a PEP;

(c) The parents of a PEP.

Close associates of a Politically Exposed Person are defined as:

(d) Individuals who jointly own legal entities or legal arrangements with a PEP or maintain close business relationships with a PEP;

(e) Individuals who solely own a legal entity or arrangement set up for the benefit of a PEP.

CRYPTOWITS has determined that PEPs, their family members, and known close associates of PEPs fall outside its risk appetite. Therefore, CRYPTOWITS does not permit these individuals to access its products or services.

Sanctions Policy.

In line with our commitment to robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) practices and compliance with applicable laws and international financial sanctions, CRYPTOWITS enforces a strict Sanctions Policy. This policy covers the freezing of transactions involving sanctioned entities or suspected sanctions violations, as well as the suspension or termination of services for Users engaged in such activities.

CRYPTOWITS ensures that all Users are screened against relevant sanction lists from:

• United Nations Sanctions (UN)
• US Consolidated Sanctions
• OFAC – Specially Designated Nationals (SDN)
• EU Financial Sanctions
• UK Financial Sanctions (HMT)
• Australian Sanctions
• Switzerland Sanction List – SECO
• INTERPOL Wanted List
• Consolidated Canadian Autonomous Sanctions List
• Office of the Superintendent of Financial Institutions (Canada)
• Bureau of Industry and Security (US)
• Department of State, AECA Debarred List (US)
• Department of State, Nonproliferation Sanctions (US)
• and others.

We maintain compliance with all relevant regulatory, legislative, economic, and financial sanctions requirements by conducting sanctions screening on all Users and third parties before initiating business relationships and continuously throughout the relationship.

Our Sanctions Policy strictly prohibits any dealings with Users involved in money laundering or terrorist financing. This prohibition applies if CRYPTOWITS becomes aware of or suspects involvement in such activities or when a User relationship poses an unacceptable sanctions risk.

If there is any uncertainty about a User’s potential sanctions status or suspicion that a transaction may violate financial sanctions, CRYPTOWITS will initiate a suspension procedure and perform Due Diligence measures, including:

Collecting additional information to determine the User’s involvement in financial sanctions or violations in a transaction. This involves verifying data and documents from credible sources.

Gaining further details about the business relationship, transaction, or activity, which may include requesting additional documentation like Proof/Source of Funds, Proof of Transaction Origin, identity documents, and conducting Photo/Video verification. These materials will be validated using reliable sources.

Applying Enhanced Due Diligence measures if there is a risk or suspicion of sanctions violations.

Freezing funds and economic resources related to international financial sanctions and suspending or terminating User access to CRYPTOWITS products and services.

If, after Due Diligence, CRYPTOWITS confirms that a User is subject to financial sanctions or that their transaction violates sanctions, or if Enhanced Due Diligence does not resolve the issue, we will freeze the funds involved and suspend the User. We will also promptly report these findings or suspicions to the relevant regulatory authorities.

Moreover, if during Due Diligence, CRYPTOWITS identifies that a transaction involves a sanctioned entity or related third party, the User is fully responsible for that transaction, including its execution, any subsequent Due Diligence procedures, potential freezing of involved funds, and further suspension of the User.

High-Risk Countries.

Government and international agencies identify countries whose financial or social systems present a high risk of money laundering. Regulations mandate additional due diligence checks when dealing with individuals or funds from these high-risk countries, taking into account specific concerns raised by national or international bodies.

CRYPTOWITS prohibits the use of its products and services for citizens and/or residents of the following countries, territories, and jurisdictions*: Afghanistan, American Samoa, U.S. Virgin Islands, Guam, Iran, Yemen, Libya, Palestine, Puerto Rico, Somalia, North Korea, Northern Mariana Islands, USA, Syria, Russia, Belarus, Sudan, Transnistria, temporarily occupied territories of Georgia, Northern Cyprus, Western Sahara, Amazonia, Kosovo, South Sudan, Canada, United Kingdom, Nicaragua, Trinidad and Tobago, Venezuela, Myanmar, and temporarily occupied territories of Ukraine.

*Note that this list of prohibited and high-risk jurisdictions is subject to ongoing updates by CRYPTOWITS in accordance with current laws and regulations. It is your responsibility to check our Website for the most current version.

Customer Transaction Monitoring.

Following a User’s onboarding, CRYPTOWITS implements comprehensive transaction monitoring procedures using advanced, internally developed fraud prevention and risk management systems to maintain vigilance throughout the business relationship.

The vigilance measures include:

• Transaction Monitoring: Continuously monitoring transactions initiated by customers to detect any unusual, fraudulent, or criminal activity, or deviations from typical patterns based on the User’s profile and the risk associated with the business relationship. This process utilizes both automated and manual tools with predefined criteria, parameters, and thresholds.
• Sanctions Compliance: Assessing transactions to ensure they do not involve sanctioned individuals or entities, in accordance with recognized Sanction Lists.
• Regular Customer File Updates: Periodically updating User files in line with the KYC/AML risk review schedules established for each User.
• Risk Rating Updates: Revising the User’s risk rating during regular reviews or after significant changes in the business relationship, such as the User becoming a Politically Exposed Person (PEP), or based on Adverse Media and third-party alerts.
• Validation of High-Risk Operations: Ensuring that high-risk operations are validated according to AML/CTF compliance procedures.

Continuous monitoring may lead to adjustments in the User’s risk rating and the application of enhanced surveillance when transactions are flagged as atypical, such as suspicious transaction reports (STRs), alerts, or multiple enhanced reviews.

CRYPTOWITS also reserves the right to block both incoming and outgoing questionable or sanctioned transactions (including those involving sanctioned entities). This may involve freezing funds associated with such transactions and suspending or terminating access to CRYPTOWITS’s products and services.

Red-flags, Abnormal activity, Unusual behavior, or Questionable conduct

A transaction that triggers red flags, abnormal activity, unusual behavior, or questionable conduct typically deviates from a User’s established legitimate business or personal activities or from the usual transaction patterns for that User profile. Therefore, understanding the User’s business is crucial for identifying any unusual or irregular transactions.

CRYPTOWITS collects proof of the destination of funds and the identity of the beneficiary from Users, along with information on the origin of the funds and the purpose of the transaction.

While documents such as bank statements or cash declarations, which indicate the origin of funds (e.g., inheritance or real estate sale), can be provided, they alone may not fully justify the source of funds. Declarations or attestations from Users may not be considered sufficient to confirm the legitimacy of the source.

If a User refuses to disclose relevant evidence under the guise of business or professional secrecy, CRYPTOWITS will treat this as a significant concern. Persistent doubts in this situation warrant further scrutiny.

In compliance with AML/CTF international laws and regulations, CRYPTOWITS adheres to all required procedures, including collecting all necessary additional documents and information from Users as part of its AML/CTF policies.

AML Compliance Officer (Money Laundering Reporting Officer (MLRO).

The AML Compliance Officer (also known as the Money Laundering Reporting Officer or MLRO), who is authorized by CRYPTOWITS, is responsible for overseeing and ensuring the effective implementation of Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) measures. This role includes the obligation to report any breaches of AML/CTF protocols and manage the collection and submission of Suspicious Activity Reports (SARs).

The AML Compliance Officer’s responsibilities include:

• Developing and Updating Policies: Establishing and regularly updating internal AML/CTF policies and procedures to ensure compliance with relevant laws and regulations. This includes managing the completion, review, submission, and retention of required reports and records.
• User Identification and Record Management: Collecting and verifying Users’ identification information, and implementing a record management system for proper document storage and retrieval.
• Transaction Analysis: Gathering and analyzing information related to unusual transactions or suspected criminal activity, including money laundering or terrorist financing.
• Investigations: Conducting investigations into identified unusual or criminal activities.
• Reporting: Promptly reporting instances of money laundering or terrorist financing to the appropriate authorities and providing necessary information in accordance with regulations.
• Compliance Statements: Periodically providing written statements to the management board to affirm compliance with legal requirements.
• Training Programs: Organizing training programs for staff to ensure awareness and adherence to AML/CTF policies.
• Risk Assessment: Regularly updating risk assessments to reflect changing circumstances and regulatory requirements.
• Authority Interaction: Engaging with law enforcement and regulatory authorities involved in combating money laundering, terrorist financing, and other illegal activities.

The Compliance Officer is authorized to interact with relevant authorities to ensure effective enforcement of AML/CTF measures and address any issues related to legal compliance.

AML/CTF Training.

CRYPTOWITS ensures that specialists receive thorough AML/CTF training, which includes job-specific guidance. This training is conducted at least every six (6) months to keep specialists informed and compliant with relevant laws and regulations. Additional training sessions are held as necessary, particularly in response to new laws, regulations, or legal requirements.

The AML/CTF Training Program is regularly updated to reflect the latest legal standards and regulatory changes, maintaining its relevance and compliance.

Record-Keeping and Documentation.

CRYPTOWITS will retain the following records for five (5) years after the end of the User relationship:

• Copies or references to evidence obtained regarding a User’s identity and details of User trading activities from the date of the relevant transaction.
• All User communications, including emails and recorded calls.

Additionally, CRYPTOWITS will keep internal records for five (5) years, including:

• Documentation of all AML/CTF Training sessions conducted.
• Records of actions taken in response to both internal and external reports.
• Information reviewed by the AML Compliance Officer or their nominee concerning internal reports where no external report is filed.

CRYPTOWITS is committed to strict adherence to these record-keeping requirements and will ensure that documents are available for review upon request.

Amendments and Final provisions.

This AML/CTF Policy is effective from the date of publication on our Website and will remain in effect until amended. Any changes to this policy will be applied immediately upon their publication on our Website.

We may update or modify the terms of this AML/CTF Policy, and it is your responsibility to review any relevant updates.

If you disagree with this AML/CTF Policy, please refrain from using our Website, mobile application, or Services, or from opening an Account. This AML/CTF Policy forms an integral part of our User Agreement.

For any questions regarding this AML/CTF Policy, please contact our AML Department.