Xprocoinpay AML/CTF Policy
Anti-Money Laundering & Counter-Terrorism Financing Policy (“AML/CTF Policy”) sets out the processes and controls to help us prevent, identify, manage, and mitigate risks of us being involved in any kind of illegal activity, in particular money laundering. Money laundering (ML) and terrorist financing (TF) are one of the biggest challenges faced by the crypto and financial communities today. Xprocoinpay considers ML/TF as a serious threat, and therefore introduces and implements its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy in accordance with the relevant legal acts, recommendations, guidelines, and best practices in the global financial sector. Xprocoinpay is fully committed to providing reputable, reliable, and secure services with high standards of integrity and transparency, in full compliance with applicable laws and global standards.
The following are the major points on which our compliance and risk assessment teams Xprocoinpay Focus. We Lead, Coordinate and Monitor continuously and vigorously according to the International and EBA Rules
In-Depth Customer and Employee Due Diligence ||
Customer due diligence information comprises the facts about a customer that should enable Xprocoinpay to assess the extent to which the customer exposes it to a range of risks. Customer due diligence information is obtained from the customer before establishing the business relationship with him/her/it. Xprocoinpay also verifies the obtained information against reliable and independent sources both local and global. We take very seriously the authenticity of the documents and thus request real images with true ID and not scan or downloaded contents.
By collecting and verifying the customer’s information the Company aims to form a reasonable belief as to the real identity of the customer. Xprocoinpay must also understand the business of the customer to make sure that the customer does not launder illicit funds through XproCoins and/or these funds will not be used for TF. Information, documents, and data provided to Xprocoinpay during the identification of the customer are processed in accordance with Xprocoinpay’s Privacy Policy, very strict GDPR regulations and confidentiality laws. Employee Due Diligence and Risk Awareness Training is also very important at Xprocoinpay – we screen all employees and conduct additional background checks on entrusted employees. We provide training for all relevant employees on an ongoing basis.
Continues Updating of Information ||
Xprocoinpay performs ongoing monitoring of the business relationships with customers. Ongoing monitoring and updating are performed on all business relationships regardless of their risk rating under the risk-based approach. However, the degree and nature of monitoring will depend on the risk rating of the customer and the service provided.
Risk Assessment & Management ||
While assessing the risks, Xprocoinpay applies the risk-based approach. It means that Xprocoinpay understands the ML/TF risks to which it is exposed and applies AML/CFT measures in a manner and to an extent that would ensure mitigation of these risks. This flexibility enables Xprocoinpay to focus its resources and take enhanced measures in situations where the risks are higher.
Ongoing monitoring allows Xprocoinpay to gain deeper insights into customers’ profiles and behaviors and strengthen risk-based allocation of resources to tackle higher risk areas.
Record-Keeping ||
Xprocoinpay maintains appropriate records in relation to every customer, with the idea being that maintaining an adequate audit trail is a significant component of combating ML/TF. Record keeping is essential to facilitate the effective investigation, prosecution, and confiscation of criminal property. If the funds used to finance terrorist activity cannot be traced back through the financial system, then the sources and the destination of terrorist financing will not be identified. Money Laundering Reporting Officer (MLRO) – we have appointed an MLRO with a sufficient level of seniority, who has responsibility for oversight of compliance with the relevant legislation, regulations, rules, and industry guidance.
Suspicious Reporting ||
We report suspicious activity to the relevant law enforcement authorities in all jurisdictions we operate.
Transaction Monitoring & Ongoing Monitoring ||
We analyze data and transactional patterns as a risk assessment and suspicion detection tool.
Communication with Competent Authorities ||
Upon suspicion or any knowledge that the property of any value is directly or indirectly derived from criminal activity or participation in such activity, or that the intended purpose of property is to sponsor one or several terrorists or terrorist organization, Xprocoinpay will report that to the competent authorities and will cooperate on any follow-up actions.
