AML and KYC policy

This policy describes the anti-money-laundering and counter-terrorist-financing measures the Platform applies to every Client and every transaction. It is binding on staff and cannot be waived at a Client’s request.

The measures follow UAE law and FATF recommendations. The Platform appoints a compliance officer who reports directly to management and has the authority to halt any transaction.

A venue that never asks for verification usually has no licence either. The absence of checks is not convenience — it is a warning sign.

Verification is mandatory before the first withdrawal. The Client provides a valid identity document and a selfie with it to confirm the document belongs to them.

• Basic level: document and selfie. Opens withdrawals within standard limits.
• Extended level: proof of residential address in addition. Required once cumulative turnover reaches USD 50,000.
• Enhanced due diligence: proof of source of funds. Required for large amounts, unusual activity and politically exposed persons.

The Platform may require re-verification when a document expires, when the Client’s details change, or when there are signs that the account has been compromised.

For large deposits the Platform requests proof of where the money came from: a statement of income, documents on the sale of property, or a bank or exchange statement.

Until that proof is provided the funds may be credited, but withdrawals are suspended. If proof is not provided within a reasonable time, the Platform returns the funds to the original sending address.

Every transaction goes through automated checks. The system weighs the amount, frequency, country, address history and consistency with the Client’s profile, assigning each transaction a risk level.

• Splitting amounts to stay under limits.
• Withdrawing immediately after a deposit without placing the funds.
• Deposits from addresses linked to mixers, darknet marketplaces or known hacks.
• Turnover inconsistent with the declared profile and source of income.

Higher-risk transactions are reviewed manually by a compliance officer before they are executed.

Clients are screened against the sanctions lists of the UN, the UAE, the USA, the European Union and the United Kingdom at registration and regularly thereafter. Wallet addresses are also screened against blockchain analytics databases.

A match on a sanctions list results in the account being blocked immediately and the competent authority being notified. Funds are not returned until the appropriate authorisation is received.

For transfers between virtual asset service providers, the Platform sends and receives originator and beneficiary information to the extent required by the FATF Travel Rule.

Transfers to addresses that cannot be identified, or that are linked to anonymising services, may be declined.

The Platform may refuse service without stating reasons, suspend transactions and freeze funds where it suspects a breach of this policy.

Suspicious transactions are reported to the competent authority. The law prohibits telling the Client that such a report has been made, so we will not be able to explain the details.

Verification and transaction records are kept for at least five years after the relationship with the Client ends.

Staff with access to Client transactions receive anti-money-laundering training when they join and annually thereafter.

The effectiveness of these procedures is tested by independent audit. Any shortcomings found are remedied within an agreed period, and the report is provided to the regulator on request.