CryptoFinEx LLC is committed to combating money laundering, terrorist financing, and other financial crimes. We operate in full compliance with the US Bank Secrecy Act (BSA), FinCEN regulations, OFAC sanctions, and international AML/CFT standards. This policy outlines our procedures to detect, prevent, and report suspicious activities.
1. Customer Due Diligence (CDD)
We verify the identity of all customers through our KYC process, which requires:
- Government-issued photo ID (passport, driver's license, national ID)
- Proof of address (utility bill, bank statement dated within 3 months)
- Source of funds declaration
- Beneficial ownership identification for legal entities
- Enhanced due diligence for high-risk customers
2. Transaction Monitoring
Our automated monitoring system continuously analyzes transactions for suspicious patterns, including:
- Large or rapid transactions inconsistent with customer profile
- Structuring (small transactions to avoid reporting)
- Transactions from sanctioned addresses or high-risk jurisdictions
- Rapid deposits followed by immediate withdrawals
- Unusual trading patterns or market manipulation
3. Suspicious Activity Reporting (SAR)
We are legally obligated to file Suspicious Activity Reports (SARs) with FinCEN for any transaction of $2,000 or more that we suspect involves illegal activity. Customer confidentiality regarding SAR filings is strictly maintained under federal law.
4. Sanctions Screening
We screen all customers and transactions against global sanctions lists, including: OFAC SDN List, UN Security Council Sanctions, EU Consolidated List, UK HMT Sanctions. We block any transactions involving sanctioned individuals or entities and report to authorities.
5. Prohibited Jurisdictions
We do not accept customers or process transactions from: North Korea, Iran, Syria, Crimea region of Ukraine, Cuba, and any other country subject to comprehensive US sanctions. We also restrict high-risk jurisdictions as identified by FATF.
6. Record Keeping
We maintain all transaction records, customer identification documents, and SAR filings for a minimum of 5 years as required by FinCEN regulations (31 CFR § 1010.410). Records are stored securely and are available for regulatory inspection.
7. AML Compliance Officer
Our designated AML Compliance Officer oversees all AML/CFT programs, conducts risk assessments, coordinates with regulators, and ensures ongoing staff training. Contact: aml@cryptofinex.com
8. Customer Obligations
By using our platform, you agree to:
- ✓Provide accurate and current identification information
- ✓Immediately update any changes to your information
- ✓Not use the platform for any illegal activities
- ✓Cooperate with AML inquiries and investigations
- ✓Report any suspicious activity to our compliance team
9. Penalties for Non-Compliance
Violations of AML laws carry severe penalties including civil fines up to $1 million per violation, criminal prosecution with imprisonment up to 20 years, and asset forfeiture. We cooperate fully with law enforcement investigations.
10. Policy Review & Updates
This AML Policy is reviewed annually and updated as regulations evolve. Material changes will be communicated to customers via platform notification and email.
11. Reporting Suspicious Activity
If you suspect money laundering or terrorist financing on our platform, please report immediately to our AML Compliance Officer: aml@cryptofinex.com. Reports can be made anonymously under federal Whistleblower Protection laws.