AML/KYC Policies and Procedures of XT.com - Version 3

This Policy relates to XT.com’s anti-money laundering and countering the financing of terrorism (“AML/KYC”) policies and procedures. This Policy is solely for the purpose of providing general information and is not, in any way, legally binding either on XT.com and/or on any other person(s) (natural or otherwise), does not create any obligation, duty, or reliance by any third party.

 

A. XT.com’s Principles and Approach to AML/KYC Efforts

XT.com is committed to supporting AML/KYC efforts. In principle, we are committed to, amongst other things:

1. exercising due diligence when dealing with our customers, natural persons appointed to act for our customers ‘behalf;
2. conducting our business in conformity with high ethical standards, and to, as far as possible, guard against establishing any business relations that is or may be connected with or may facilitate money-laundering or terrorism-financing;
3. We will, to the fullest extent possible, assist and cooperate with relevant law authorities to prevent the threat of money-laundering and terrorism-financing.

B. XT.com’s Approach to Risk Assessment and Risk Mitigation

Risk Assessment

We envisage that the majority of our customers would be retail customers. In this regard, we would:

a. document and/or collect documentation in relation to:

1. the identities of our customers;
2. the countries or jurisdictions that our customers are from or in; and

b. ensure that, to the best of our knowledge, skill and ability, our customers, connected persons of a customer, natural persons appointed to act on behalf of a customer, beneficial owners of a customer will be assessed and screened with the assistance of List of Designated Individuals and Entities which include categories such as:

1. the Democratic People’s Republic of Korea;
2. the Democratic Republic of the Congo;
3. Libya;
4. Somalia;
5. South Sudan;
6. Sudan;
7. Yemen;
8. the UN 1267/1989 Al-Qaida List;
9. the UN 1988 Taliban List;
10. persons identified in the First Schedule of the Terrorism (Suppression of Financing) Act (Cap. 325).

Risk Mitigation

If identified, we will not deal with any persons identified in the List of Designated Individuals and Entities.

 

C. Our Approach to New Products, Practices and Technologies

We will be properly advised, in relation to, identifying and assessing the money laundering and terrorism financing risks that may arise in relation to:

1. the development of new products and new business practices, including new delivery mechanisms;
2. the use of new or developing technologies for both new and pre- existing

D. Our Approach to Customer Due Diligence (“CDD”)

We do not open, maintain or accept anonymous accounts or accounts in fictitious names.

We do not establish business relations with, or undertake a transaction for a customer that we have any reasonable grounds to suspect that the assets or funds of a customer are proceeds of drug dealing or criminal conduct. We may lodge a Suspicious Transaction Report and extend a copy to the relevant Financial Intelligence Unit for such transactions.

We perform Customer Due Diligence:

1. when we establish business relations with any customer;
2. when we undertake any transaction for any customer whom we had not established business relations with;
3. when we effect or receive digital payment tokens by value transfer for any customer whom we had not established business relations with;
4. when we have suspicion of money-laundering or terrorism financing;
5. when we have doubts about the veracity or adequacy of any information

Verifying the Identities of our Customers

We will verify the identities of our customers using reliable, independent source data, documents or information. Where our customer is a legal person or legal arrangement, we will verify the legal form, proof of existence, constitution and powers that regulate and bind the customer, using reliable, independent source data, documents or information.

 

Ongoing Monitoring

We will monitor business relations with our customers on an ongoing basis. We will , during the course of business relations with a customer, observe the conduct of the customer’s account and scrutinise transactions undertaken throughout the course of business relations, to ensure that the transactions are consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds.

 

We will pay special attention to all complex, unusually large or unusual patterns of transactions, undertaken throughout the course of business relations, that have no apparent or visible economic or lawful purpose. We will , to the extent possible, inquire into the background and purpose of the aforesaid transactions and document its findings with a view to making this information available to the relevant authorities should the need arise.

For the purposes of ongoing monitoring, we will put in place and implement adequate systems and processes, commensurate with the size and complexity of the payment service provider to:

1. monitor its business relations with customers; and
2. detect and report suspicious, complex, unusually large or unusual patterns of transactions undertaken throughout the course of business relations.

We will ensure that the CDD data, documents and information obtained in respect of customers, natural persons appointed to act on behalf of the customers, connected parties of the customers and beneficial owners of the customers, are relevant and kept up-to-date by undertaking reviews of existing CDD data, documents and information, particularly for higher risk categories of customers.

Where there are any reasonable grounds for suspicion that existing business relations with a customer are connected with money laundering or terrorism financing, and where we consider it appropriate to retain the customer:

1. we will substantiate and document the reasons for retaining the customer; and
2. the customer’s business relations with us will be subject to commensurate risk mitigation measures, including enhanced ongoing monitoring.

Screening

We will screen a customer, natural persons appointed to act on behalf of the customer, connected parties of the customer and beneficial owners of the customer against relevant money laundering and terrorism financing information sources, as well as lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks in relation to the customer.

We will screen the people:

1. when, or as soon as reasonably practicable after, we establish business relations with a customer;
2. before we effect or receive digital payment tokens by value transfer, for a customer who has not otherwise established business relations with us;
3. on a periodic basis after we establish business relations with our customers; and
4. when there are any changes or updates to:
5. the lists and information provided by the Authority to the payment service provider; or
6. the natural persons appointed to act on behalf of a customer, connected parties of a customer or beneficial owners

We will screen all value transfer originators and value transfer beneficiaries, against lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks.

We will document the results of all screenings.

 

E. Our Approach to Enhanced Customer Due Diligence

Politically Exposed Persons

We will use reasonable means to determine if a customer, any natural person appointed to act on behalf of a customer, any connected party of the customer or any beneficial owner of the customer is a politically exposed person, or a family member or close associate of a politically exposed person.

 

We will , in addition to performing CDD measures, perform at least the following enhanced due diligence measures where a customer or any beneficial owner of the customer is determined by us to be a politically exposed person, or a family member or close associate of a politically exposed person:

1. obtain approval from senior management to establish and continue business relations with the customer;
2. establish by reasonable means, the source of wealth and source of funds of the customer and any beneficial owner of the customer; and
3. conduct, during the course of business relations with the customer, enhanced monitoring of the business relations with the customer. We will increase the degree and nature of monitoring for any transactions that appear unusual

Higher Risk Categories

We recognise that the following circumstances where a customer presents or may present a higher risk for money laundering or terrorism financing include but are not limited to the following:

1. where a customer or any beneficial owner of the customer is from or in a country or jurisdiction in relation to which the FATF has called for countermeasures, the payment service provider will treat any business relations with or transactions for any such customer as presenting a higher risk for money laundering or terrorism financing; and
2. where a customer or any beneficial owner of the customer is from or in a country or jurisdiction known to have inadequate AML/CFT measures, as determined by the payment service provider for itself or notified to payment service providers generally by the Authority or other foreign regulatory authorities, the payment service provider will assess whether any such customer presents a higher risk for money laundering or terrorism

We will perform enhanced CDD for customers who present a higher risk for money laundering or terrorism financing or any customer the Authority notifies to us as presenting a higher risk for money laundering and terrorism financing.
 

F. Record Keeping

We will keep proper records as required for a time period of at least 5 years.

 

G. Personal Data*

We will safeguard the personal data of our customers in the manner prescribed.

 

H. Suspicious Transactions Reporting (“STR”)

We will inform the relevant authorities and file STR Reports as required by law. We will also keep all records and transactions relating to all such transactions and STR Reports.

 

I. Our Policies on Compliance, Audit and Training

Amongst other things, we will appoint an AML/CFT Compliance Officer at the Management Level, maintain an independent audit function, and take proactive measures in regularly training our employees and employees on AML/CFT matters.