Anti-Money Laundering Policy.

24IEX is committed to maintaining effective crime prevention and detection measures to assist law enforcement agencies in combating financial crime. The site has adopted a strict set of policies and procedures to comply with its legal obligations under international anti-money laundering and terrorism laws.

Background Information

Money laundering is the process, i.e., any action or attempted action, in which money and property (assets) obtained through criminal activity are disguised as coming from a legitimate source. Essentially, money laundering is the process by which "dirty money" obtained through criminal activity is transformed into "clean money," the criminal origin of which is difficult to trace.

The money laundering process consists of three stages:

Placement involves placing criminal proceeds into the financial system.
Distribution involves transforming criminal proceeds into another form and creating complex layers of financial transactions to complicate control and conceal the source and ownership of the proceeds.
Integration involves returning laundered proceeds to the economy and creating a sense of legitimacy.

Money laundering begins with the proceeds of a crime derived from a predicate offense. Predicate offenses include tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeiting, securities manipulation, and copyright infringement, among others. A money laundering offense may involve property or proceeds derived from illegal activity.

Terrorist financing is knowingly collecting or providing property, such as money, directly or indirectly to terrorists. The primary purpose of terrorist activity is to intimidate the public or force government action. Terrorists require financial support to carry out terrorist activities and achieve their goals. Many of the same techniques used for money laundering are also used in terrorist financing, including, but not limited to, concealing the flow of funds and using third parties. They need to disguise their funds as coming from another source and transform them into a form that cannot be easily traced so they can be used.

1. Primary Objectives

Customers' identities are properly verified in accordance with the company's risk-based approach before the website engages in business with them.
The website knows its customers and understands their reasons for doing business with us, both at the decision-making stage and throughout the relationship.
Our employees are trained and aware of both their personal legal obligations and the website's legal obligations.
Our employees are trained to be vigilant regarding activity where there are reasonable grounds to suspect money laundering is occurring and to report it to the compliance officer. Sufficient records are retained for the required period.
We establish, maintain, and implement appropriate procedures to achieve these objectives.

2. General Principles

Anti-Money Laundering Policy

Cryptomus has implemented policies, procedures, and controls designed to prevent criminals from using the website to launder the proceeds of crime. These policies and procedures are tailored to the risk posed to individual clients.

Customer Due Diligence (CDD)

Cryptomus has established customer due diligence procedures to identify users of its services and, for higher-risk clients, the underlying beneficial owners and source of funds. These procedures include knowledge of the nature of our clients' businesses and vigilance for anomalous transactions.

Overall, the CDD policy has been adopted on the website to successfully accomplish the following objectives:

identification and verification of the business applicant;
identification and verification of the beneficial owner, where applicable;
identification and verification where the business applicant is not acting as a principal;
Obtaining information about the purpose and intended nature of the business relationship;
Conducting ongoing monitoring of the business relationship;
Establishing the source of wealth and the source of funds;
Developing a client acceptance policy and ensuring that the business applicant meets the requirements set forth in such policy;
Anonymous accounts or accounts under fictitious names are strictly prohibited on the website.

Suspicious transactions

About unexplainedAny unusual or abnormal transactions or actions suspected of being related to criminal activity should be promptly reported in writing to the Compliance Officer, who will determine whether the suspicion should be reported to law enforcement.

Training

All personnel must be informed of their individual and collective responsibilities and the Website's anti-money laundering policies. Personnel are provided with training to understand the Website's business vulnerabilities and to recognize and report suspicious activity.

Recordkeeping

The Website maintains records of training received, the timing, and the form in which training was conducted. We retain all records verifying the identity of our clients for at least seven years after the end of the business relationship. We also maintain records of any internal reports of suspicion directed to the Compliance Officer.

3. Our Responsibilities

International law obliges all financial services firms to:

Develop a program to ensure compliance with reporting, recordkeeping, and client identification requirements;

Adhere to customer identification rules and maintain specific transaction records;

Report suspicious transactions, large cash transactions, and information related to terrorist assets.

4. Risk-Based Approach

What is risk? - Risk can be defined as the likelihood of an event occurring and its consequences. Simply put, risk can be thought of as a combination of the likelihood that something might happen and the degree of damage or loss that could result from that event. In the context of money laundering/terrorist financing (ML/TF), risk refers to:

At the national level: ML/TF threats and vulnerabilities that compromise the integrity of the financial system.
At the company level: threats and vulnerabilities that expose the company to the risk of ML/TF abuse.

By default, all clients are categorized as low risk UNLESS the following risk factors are present: Automatic high risk characteristics - If any of the following flags are present, the client is categorized as high risk.

Politically Exposed Person
A client for whom a suspicious transaction report (STR) or terrorist financing report has been filed
A client who is an identified terrorist
A client for whom we are unable to obtain beneficial ownership information
A client from a high-risk country

Client characteristics, product, service, and delivery channel:

Politically Exposed Person, head of an international organization, and their close associates;
Unknown source of funds;
Orders for large transactions (ETFs) from/to high-risk foreign jurisdictions;
Involvement of third parties without reasonable justification;
Occupation – high-risk activities (e.g., cash-intensive businesses, offshore businesses, businesses in high-risk countries, online gambling);
The client's business structure or transactions appear unusually complex;
Inability to personally identify the client without a valid reason.

Geography:

The client resides outside the local or usual client area;
The client resides in an area with high crime rates;
The client conducts offshore business or has connections to high-risk countries.

Other indicators of suspicious transactions:

Transaction volume/timing/complexity inconsistent with the client's personal/business activities and/or the purpose of the services/account;
Deposit/transfer value inconsistent with the client's occupation or source of funds;
Presence of any of the indicators of suspicious transactions specified in the "Background Information" section of Part A.

5. Indicators of Suspicious Transactions or Potentially High-Risk Clients

Below are examples of some common and industry-specific indicators that may give you reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. The presence of one or more of these factors does not mean the transaction is suspicious and should be reported to the regulator, but it does indicate the need for further investigation.

Common Indicators Below are some examples of common indicators that may lead us to suspect that a transaction is related to money laundering or terrorist financing. It will not be just one of these factors, but a combination of several factors, combined with what is normal and reasonable in the circumstances of the transaction or attempted transaction.

The customer admits or makes allegations of involvement in criminal activity;
The customer refuses or attempts to avoid providing requested information, or provides information that is misleading, vague, or difficult to verify;
The customer provides documentation that appears to be false, altered, or inaccurate;
The customer appears to have accounts in multiple countries.financial institutions in the same region for no apparent reason;
The client repeatedly uses the same address but frequently changes the name listed there;
The client displays unusual curiosity about internal controls and systems;
The client provides confusing transaction details;
The client makes requests that indicate a desire to avoid reporting violations;
The client is involved in unusual activity for this individual or entity;
The client provides confusing transaction details or knows few details about its purpose;
The client appears to be knowledgeable about money laundering or terrorist financing issues;
The client refuses to provide identification documents;
The client frequently travels to high-risk countries.

Industry-Specific Examples

The client requests a transaction at an exchange rate that is higher than the published rate.
The client wishes to pay a transaction fee that exceeds the established fee.
The client is exchanging currency and requests the highest possible denomination of foreign currency bills.
The client has limited knowledge of the recipient's address and contact information, is unwilling to disclose this information, or requests a bearer document.
The client wishes to have a check issued in the same currency in lieu of a cashed check.
The client wishes to have cash converted into a check, and you do not typically issue checks.
The client wishes to exchange cash for numerous small money orders for numerous other individuals.
The client enters into transactions with counterparties in locations unusual for the client.
The client instructs a third party to collect funds on behalf of the recipient.
The client makes large purchases of travelers' checks that are inconsistent with known travel plans.
The client makes large purchases via money transfers.

6. Data Request

To reduce the risks associated with money laundering and terrorist financing, we strictly do not accept or send payments to third parties (unidentified). Each client can only send and receive payments through their own accounts, including electronic payment system accounts, bank accounts, and credit and debit cards.

In accordance with our KYC (Know Your Customer) policy, our employees are authorized to conduct client verification. In this case, the client must provide the following information:

Details of the services for which funds were received;
Screenshot confirming the receipt and withdrawal of funds;
Additional information that may be requested;

We reserve the right to refuse to process a transaction at any stage if we suspect it is related to money laundering or other criminal activity.

7. Restricted Activities and Clients

To reduce and control the risk of money laundering associated with clients, the Site does not provide services and refuses to open accounts for the following clients with an unacceptable risk level:

Individuals engaged in the following personal and/or business activities:
there is negative information about the client indicating their possible connection with proceeds of crime, money laundering, or terrorism, if the information is obtained from reliable sources such as World Check and government agency websites;
client funds have previously been frozen or seized due to suspicion of criminal activity;
reinsurance services, where the service provider does not have the proper license and there is no oversight of the service provider;
the client attempts to avoid providing information or attempts to conceal their business activity;
illegal trafficking of weapons and ammunition;
business activities that require registration as a legal entity;
Unlicensed foreign exchange brokerage services (e.g., forex dealers, binary options), and other unlicensed investment services;
The client's transactions or payments are complex, unusually large for the client's economic or personal activity, or unclear in terms of their legal and economic purpose;
Organizing/conducting escort services and/or distributing erotic/pornographic videos and photographs, as well as other related services;
Cash collection services;
Debt collection service provider;
Distribution of pharmaceuticals, vitamins, and dietary supplements;
Detective service provider;
Direct marketing service provider;
Financial pyramid schemes;
Telemarketing;
Pawn shop service provider;
Auction and related service provider;
Distribution of tobacco and alcohol products. Legal entities engaged in the following personal and/or business activities:
the client attempts to avoid providing information or attempts to conceal their economic activity;
the client has negative information indicating their possible connection with proceeds of crime, money laundering, or terrorism, if the information is receivedData from trusted sources, such as World Check and government agency websites;
client funds have previously been frozen or seized due to suspicion of criminal activity;
reinsurance services where the service provider is not properly licensed and there is a lack of supervision of the service provider;
illegal trafficking of arms and ammunition;
investment services and ancillary investment services where the service provider is not properly licensed in the European Economic Area or another country with anti-money laundering and combating the financing of terrorism (AML/CFT) legislation equivalent to EU law;
legal entities recognized as shell companies;
operating unlicensed gambling services;
the reason for the creation of the client's legal entity is unclear, and the details of the client's legal and economic purposes are unclear and ambiguous;
unlicensed foreign exchange brokerage services (e.g., forex dealers, binary options);
The client's transactions or payments are complex, unusually large for the client's economic or personal activity, or unclear in terms of their legal and economic purpose;
Organizing/hosting escort services and/or distributing erotic/pornographic videos and photographs, as well as other related services;
Cash collection services;
Debt collection service provider;
Distribution of pharmaceuticals, vitamins, and dietary supplements;
Detective service provider;
Direct marketing service provider;
Financial pyramid schemes;
Telemarketing;
Pawn shop service provider;
Auction and related service provider;
Distribution of tobacco and alcohol products
In accordance with the internal AML/CFT procedure, the website has two risk categories of clients: low-risk and high-risk. An EDD must be conducted for high-risk clients.
A high-risk client is one who:
is a politically exposed person, a member of their family, or a close associate;
with which the financial claims and liabilities arising from or related to it exceed CAD 10,000;

8. Sanctions

The Website is prohibited from transacting with persons, companies, and countries that appear on prescribed sanctions lists. Therefore, the Website will be screened against the relevant sanctions lists in the jurisdictions in which we operate.

The Website has no appetite for AML risk to establish or maintain client or counterparty relationships with any person or entity named on any of the following lists or where otherwise prohibited by applicable law or regulation:

sanctions lists administered by the U.S. Office of Foreign Assets Control (OFAC),
the United Nations (UN) Security Council Sanctions List;
the European Union (EU) Consolidated List of Financial Sanctions;
including the List of Specially Designated Nationals and Blocked Persons;
any other sanctions list.

In addition, the site pays special attention to entities from countries on the Financial Action Task Force (FATF) list of non-cooperative countries and territories, as well as monetary transactions carried out by them or on their behalf.

9. List of Unserved Countries

The website does not open accounts or provide services to clients from the following countries:

Islamic Republic of Afghanistan (AF)
Republic of Angola (AO)
Belarus (BY)
Bosnia and Herzegovina (BA)
Republic of Botswana (BG)
Commonwealth of the Bahamas (BS)
Kingdom of Cambodia (CM)
Republic of Burundi (BI)
Democratic Republic of the Congo (CD)
Central African Republic (CF)
Republic of the Congo (CG)
People's Democratic Republic of Algeria (DZ)
Republic of Ecuador (EU)
State of Eritrea (IS)
Federal Democratic Republic of Ethiopia (ET)
Republic of Ghana (GH)
Republic of Guinea (GN)
Republic of Guinea-Bissau (GW)
Cooperative Republic of Guyana (GY)
Republic of Haiti (HT)
Republic of Iraq (IQ)
Islamic Republic of Iran (IR)
Japan JP
Republic of Kenya KE
Democratic People's Republic of Korea KP
Lebanese Republic LB
Republic of Liberia LR
Libya LY
Republic of the Union of Myanmar MM
Federal Republic of Nigeria
Islamic Republic of Pakistan PK
Republic of Serbia RS
Republic of the Sudan SD
Democratic Socialist Republic of Sri Lanka SL
Federal Republic of Somalia SO
Republic of South Sudan SS
Syrian Arab Republic SY
Tunisia TN
Republic of Trinidad and Tobago TT
Ukraine UKR
Republic of Uganda I
United States of America US
Republic of Vanuatu VU
Bolivarian Republic of Venezuela VE
Republic of Yemen YE
Republic of Zimbabwe ZW

10. Suspicious Activity Monitoring

The website's AML policy includes We maintain client and beneficial owner due diligence and a policy of ongoing AML monitoring and reporting. At various times, the website may request information about transactions conducted through the client's account, opened The website and the parties to the relevant payment. If the client fails to respond sufficiently or in a timely manner, the website also reserves the right to reject any relevant payments in accordance with applicable AML laws and regulations.

AML and KYC Policy