{{appName}} AML Anti-Money Laundering and Counter-Terrorist Financing Statement {{appName}} (referred to as '{{appName}}', 'us', 'our', 'we') which is an e-money product dedicated to facilitating transactions and the provision of related services. By browsing, visiting or using {{appName}}, our APP and exchange service (collectively, service), you ('user') shall be deemed to have understood and agreed to all of the terms and conditions of this statement. Please carefully review and consider the terms of this statement, if you do not agree to the statement, you must immediately stop the use of the Services. We may at any time amend this statement, include but not limited to any policy or instruction on the platform. We shall notify you these changes either through marking the amended versions with latest release date on the top of the statement, or any other method we decide that is appropriate. Any changes or modifications will take effective immediately upon posting on this website and applies to all current and subsequent use or services. If you continue to use any of the Services you shall be deemed to have agreed to the revised terms of this statement. If you do not agree to the statement, you must immediately stop the use of the Services. You are advised to review the statement regularly to ensure that you understand the terms and conditions. 1. This statement is a summary of the policies and procedures which we have implemented to reduce the risk of money laundering and terrorist financing. This statement only covers the use of the {{appName}} and other policies may apply for customers receiving separate services from us or our partners (such as the use of a debit card). 2. Due to new UK anti-money laundering legislation which is due to enter into force on 10 January 2020, {{appName}} will become subject to the UK anti-money laundering regime. As a matter of best practice, we have decided to comply with these requirements before this date. We are already subject to a number of other laws in the UK, including the Proceeds of Crime Act 2002 and the Terrorism Act 2000. What is money laundering/terrorist financing? 1. Money Laundering is the process whereby criminals conceal the actual ownership and origin of the proceeds of criminal activities. The phrase ‘money laundering’ can cover all methods used to obscure the identity of illegally obtained assets so that they can be used for legitimate purposes. 2. Terrorist financing is the use of financial systems and infrastructure to fund terrorism. Customer Due Diligence 3. We will seek from customers such information as is necessary in order to verify their identity in accordance with the requirements which exist under the UK's anti-money laundering regime. We may use third party sources to verify information about customers or may require customers to produce copies of documents which evidence their identity. 4. Customer due diligence will be conducted on a risk-sensitive basis, with customers posing the highest risk being required to provide more information than customers who pose a low risk. We have in place policies and procedures to recognise when there is a higher risk of money laundering. Customers who are also considered politically exposed persons (PEPs) will be identified and be subject to a more stringent verification procedure. 5. If we are unable to verify a customer's identity, we will not enter into a business relationship with that customer or allow that customer to make a transaction on the {{appName}}. If we consider that a customer poses a sufficiently high risk of money laundering then we will not enter into a business relationship with that customer. 6. Evidence of a customer's identity will be retained by us for at least 5 years from the date that the relationship with the customer comes to an end. All data collected by us in discharging its anti-money laundering obligations will be processed in accordance with our privacy policy which can be found on the website. Transaction Monitoring 7. Once a customer's identity has been verified, we have ongoing obligations to monitor transactions which occur on the {{appName}} to determine whether a customer's transactions are suspicious. 8. We have in place policies and procedures which allow us to recognise which transactions are suspicious and merit further investigation. Organisational Procedures 9. We have appointed a Money Laundering Reporting Officer (MLRO) who will be responsible for overseeing our anti-money laundering function, ensuring that all disclosures which are required by law are made (including any suspicious activity reports) and reporting to the board of directors with an annual report on the compliance with the money laundering regime. 10. We train all relevant staff so that they are familiar with the process for verifying the identity of customers and to recognise the signs that there may be an increased risk of money laundering and how to deal with that increased level of risk. 11. The MLRO and our board of directors will regularly review the policies and procedures to ensure that they remain effective in preventing the use of the {{appName}} for money laundering and terrorist financing. Sanctions Regime 12. In addition to complying with the UK's anti-money laundering regime, we follow policies and procedures to comply with the UK's sanctions regimes. 13. Checks are undertaken to ensure that potential customers are not listed on any sanctions list maintained by the UK Government. We will not allow any person who is on a sanctions list to use the {{appName}} to make a transaction.