AML/KYC Policy
Introduction
Monetium EXCHANGE Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Monetium EXCHANGE being involved in any kind of illegal activity.

Both international and local regulations require Monetium EXCHANGE to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/KYC Policy covers the following matters:

1. Verification procedures.
2. Sanctions and PEP lists screening.
3. Compliance Officer.
4. Monitoring Transactions.
5. Risk Assessment.

1. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CIP”). According to CIP, Monetium EXCHANGE establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

“KYC” Bsaed on refers to:

1. Establish customer identity
2. Understand the nature of the customer’s activities (primary goal is to satisfy that the source of the customer’s funds is legitimate)
3. Assess money laundering risks associated with that customer for purposes of monitoring the customer’s activities

1.1. Identity verification
Monetium EXCHANGE’s identity verification procedure requires the User to provide Monetium EXCHANGE with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Monetium EXCHANGE reserves the right to collect User’s identification information for the AML/KYC Policy purposes.

Monetium EXCHANGE will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Monetium EXCHANGE reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Monetium EXCHANGE reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Monetium EXCHANGE reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Monetium EXCHANGE’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Monetium EXCHANGE is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1) Customer Identification Program (CIP)

The minimum requirements to open an individual financial account in Monetium Exchange are clearly delimited in the CIP as following steps :

1. Name
2. Date of birth
3. Address
4. Identification number ( Phone Identification )
5. ID card ( Passport )
6. Identification E mail

1.2. Bank account verification
The Users who are intended to use account in connection with the Monetium EXCHANGE’s Services have to pass account verification in accordance with instructions available on the Monetium EXCHANGE’s Site.

2. Sanctions and PEP lists screening.
Monetium EXCHANGE screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:

on the onboarding stage when the user is submitting the application;
on each anti-fraud and AML alerts manually by Compliance Officer;
monthly by running automatically with a script to re-check all DB of customers.
For the screening process performing Monetium EXCHANGE uses data (provided by AML/KYC software providers) integrated into the proprietary software and supported by World-Check One online search tool for manual confirmation.

3. Compliance Officer
The Compliance Officer is the person, duly authorized by Monetium EXCHANGE, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Monetium EXCHANGE’s anti-money laundering and counter-terrorist financing, including but not limited to:

a. Collecting Users’ identification information.
b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
c. Monitoring transactions and investigating any significant deviations from normal activity.
d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
e. Updating risk assessment regularly.
f. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

4. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Monetium EXCHANGE relies on data analysis as a risk-assessment and suspicion detection tool. Monetium EXCHANGE performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

1) Daily check of Users against recognized “black lists”, aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;

2) Case and document management.

With regard to the AML/KYC Policy, Monetium EXCHANGE will monitor all transactions and it reserves with CEZA and I-wave the right to:

ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
request the User to provide any additional information and documents in case of suspicious transactions;
suspend or terminate User’s Account when Monetium EXCHANGE has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

5. Risk Assessment
Monetium EXCHANGE, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Monetium EXCHANGE is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

6  Suspicious Activity Reporting
6.1. As a regulated company, there are various regulations that need to be complied with and the company has an obligation to report suspicious activity to the relevant financial intelligent.
Failure to act on or report suspicions where there are reasonable grounds to suspect criminality, can be an offence under current legislation.
6.2 Staff are reminded of their obligations through training and refresher training and by following their obligations are helping the company protect itself against the risk of money laundering and terrorist financing and helping it comply with its legal obligations.

6.3. All staff must report suspicions as soon as possible following the procedures set out in the Reporting Suspicious Activity Policy.
To be able to report, staff must have reasonable grounds to suspect that the activity or transaction may involve proceeds of crime and or relate to terrorist financing AND have followed procedures, gathered facts as much as possible and determined there are still reasonable grounds for suspicion.

7. Customers Terrorist Financing (CTF)
7.1, Money Laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes the Company to significant criminal, regulatory and reputational risk.

7.2 This policy is designed to provide direction to staff on the approach and management of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) within the Company. This policy supports management’s objective of mitigating the following risks:
• Money laundering;
• Terrorist financing;
• Sanctions;
• Politically exposed persons (PEPs);
• Legal and regulatory risk.
This policy applies to all individuals working at all levels within the Company, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term workers, casual and agency staff, all of whom are collectively referred to as ‘staff’ in this document
7.3. Terrorist Financing
There can be considerable similarities between the movement of terrorist property and the laundering of criminal property:
some terrorist groups are known to have well established links with organizing criminal activity.
However, there are two major differences between terrorist property and criminal property. More generally:
• often only small amounts are required to commit individual terrorist acts, thus increasing the difficulty of tracking the terrorist property;
• terrorists can be funded from legitimately obtained income, including charitable donations, and it is extremely difficult to identify the stage at which legitimate funds become terrorist property.
The Company will ensure its staff are well versed in AML awareness and the underlying policies and procedures allowing the Company to demonstrate compliance with applicable rules and regulations in this aspect.

8.2. Staff training on anti-money laundering and counter terrorist financing will be carried out at least annually for all staff, and details will be recorded.