AML

Date:2019-05-05 05:05:47




AML POLICY

Introduction

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing your money; entering into or becoming concerned in an arrangement which you know or suspect facilitate the acquisition, retention, use or control of criminal property by or on behalf of another person; and acquiring, using or possessing criminal property. Most government requires business to submit a report to Money Laundering Office, failure to disclose knowledge or suspicion of money laundering is subject to criminal offense. This way is to reduce the likelihood of their being investigated or prejudicing an investigation.

Although bitcoins is currently unregulated however we have elected to implement systems and procedures that meet the UK AML legislation. This decision reflects Asahi Exchange’s desire that its service offering should not facilitate money laundering and not be used by criminals to launder proceeds of crime.

This Policy sets out how Asahi Exchange should formally raise concerns, in writing to the managing director and head of compliance, if we suspect money laundering or inadvertently become involved in it in some way in the course of their Asahi Exchange activities. We have a positive obligation to act should they suspect or become involved in money laundering – doing nothing is not an option and leaves staff open to criminal liability if they do not report money laundering where they suspect, or should have reasonable grounds to suspect, that it is taking place.

Policies, Controls and Procedures

Asahi Exchange is committed to establishing and maintaining policies, controls and procedures to manage and effectively mitigate the risks of money laundering and terrorist financing. These policies will be regularly reviewed to ensure that they remain fit for purpose and will include: (a) The risk management practices adopted by Asahi Exchange to prevent its business being used for money laundering and/or terrorist financing, (b) Customer due diligence requirements, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) (c) Internal controls in relation to its senior management and staff members, (d) The independent audit of its policies, controls and procedures (e) Record keeping, and (f) Monitoring compliance with its policies, controls and procedures and their communications.

VERIFICATION

a.                  Identity Verification. We require the user to provide reliable, independent identify source documents, data or information (eg. Passport, National ID Card or Drivers License). For such purposes we reserve the right to collect User’s identification information for AML Policy purposes.

b.                  Proof of Residence. We also require the user to provide reliable proof of resident (ie. Electricity Bill, Phone Bill, Bank Statement).

c.                   Confirmation. After submission of documents, we also require that you confirm that you are a real person. You are required to set-up a video call schedule wherein our team will call you. On that video call, you are required to prepare your Identification (the same identification you have submitted) and we will take a screenshot or record the entire conversation. Asahi 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 Asahi Exchange reserves the right to investigate certain Users who have been determined to be risky or suspicious.

d.                  Reservation. Asahi 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, Asahi 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 our Privacy Policy.

Credit Card verification

The Users who are intended to use payment cards in connection with the our Services have to pass card verification in accordance with instructions available on our website (http://axchange.com). 

Transaction Monitoring

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). We rely on data analysis as a risk-assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

We interact and cooperate with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity

Risk Assessment

We have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, We 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.