Anti-Money Laundering (AML) Policy for InstantExchangers

Effective Date: December 2020

1. Introduction

InstantExchangers ("we," "us," or "our") is committed to preventing money laundering and complying with anti-money laundering regulations. This Anti-Money Laundering (AML) Policy outlines our commitment to detecting and preventing money laundering activities on our platform, with a particular focus on Enhanced Due Diligence (EDD) measures.

2. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is a critical component of our AML program. We recognize that certain customers or transactions pose a higher risk of money laundering, and we implement EDD measures to mitigate these risks. EDD procedures include:

a. Monitoring for Suspicious Activity

• We actively monitor all transactions on our platform for any suspicious or unusual activity.

b. Verification of Source of Funds

• For transactions involving significant sums of money, we may require customers to provide additional documentation and information to verify the source of funds.

c. Compulsory Verification

• Any exchange that triggers suspicion or involves substantial amounts may be subject to compulsory verification. This verification process includes:
• ID Card: Customers must provide a valid government-issued identification card (e.g., passport, driver's license).
• Face Capture: Customers are required to submit a live image capture to verify their identity.
• Address Verification: Customers may need to provide documentation to verify their residential address.

These EDD measures are designed to ensure the legitimacy of transactions, enhance the security of our platform, and prevent money laundering activities.

3. AML Compliance Officer

We appoint an AML Compliance Officer who is responsible for overseeing and implementing our AML program, including EDD measures. The AML Compliance Officer ensures that our platform complies with all AML laws and regulations.

4. Reporting Suspicious Activity

We have a procedure for reporting and investigating suspicious activity on our platform. Our employees are trained to recognize and report any transactions or activities that may be indicative of money laundering or illegal activities.

5. Recordkeeping

We maintain records of all customer information, transactions, and communications as required by law. These records are kept confidential and may be provided to law enforcement or regulatory authorities upon request.

6. Non-Compliance

Non-compliance with our AML policy, including EDD procedures, may result in the suspension or termination of customer accounts and the reporting of suspicious activity to law enforcement authorities.

7. Periodic Review

We regularly review and update our AML policies and EDD procedures to stay in compliance with changing laws and regulations.

8. Customer Education

We may provide educational materials to customers to raise awareness about AML requirements and encourage their cooperation.

9. Contact Information

If you have any questions or concerns related to our AML Policy or EDD procedures, please contact us at [email protected].