ANTI MONEY LAUNDERING POLICY

PytExchange is a platform for the future of funding & exchange for the new equity cryptocurrencies.

This Policy represents the basic standards of Anti-Money Laundering (hereinafter collectively referred to as AML) procedures of PytExchange Limited. PytExchange Limited drafted its AML policy in compliance with the Federal laws with respect to money laundering which includes but not limited to the Money Laundering Control Act 1986, Money Laundering Suppression Act 1994, Money Laundering and Financial Crimes Strategy Act 2002 and Intelligence Reform and Terrorism Prevention Act 2004.

PytExchange LLC ("PytExchange LLC") has adopted an Anti-Money Laundering (AML) compliance policy ("Policy"). For avoidance of doubt and the purposes of this agreement and policy, any statement in the text below referring to PYTEXCHANGE is also referring to PytExchange LLC as the owner of this site and any reference made to PytExchange LLC.

It is the policy of PytExchange LLC to prevent and actively and tirelessly pursue the prevention of money laundering and any activity that facilitates money laundering as well as staying in line with the Combating the Financing of Terrorism (CFT). PytExchange LLC is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes. This policy is thus in effect and copies of this Policy will be distributed to all and all relevant employees must be thoroughly familiar with and make use of the material contained in this Policy.

Money Laundering

Money laundering is a generic term used to describe any process that conceals the origin or derivation of the proceeds of crime so that the proceeds appear to be derived from a legitimate source. Money laundering is sometimes wrongly regarded as an activity that is associated only with organized crime and drug trafficking. It is not. It occurs whenever any person deals with another person’s direct or indirect benefit from crime. The term ‘money laundering’ is in fact a misnomer. Often it is not money that is being laundered but other forms of property that directly or indirectly represent benefit from crime. Any form of tangible or intangible property is capable of representing another person’s benefit from crime. The main objective of the money launderer is to transform ‘dirty’ money into seemingly clean money or other assets in a way to leave as little trace as possible of the transformation. Traditionally, money laundering has been described as a process that takes place in three stages as follows:

Placement – This is the first stage in which illicit funds are separated from their illegal source. Placement involves the initial injection of the illegal funds into the financial system or carrying of cash across borders. Layering – After successfully injecting the illicit funds into the financial system, laundering them requires creating multiple layers of transactions that further separate the funds from their illegal source. The purpose of this stage is to make it more difficult to trace these funds to the illegal source. Integration – This is the final stage in a complete money laundering operation. It involves reintroducing the illegal funds into the legitimate economy. The funds now appear as clean income. The purpose of the integration of the funds is to allow the criminal to use the funds without raising suspicion that might trigger investigation and pursuit. In reality, the three stages often overlap and the benefit from many crimes including most financial crimes does not need to be ‘placed’ into the financial system. Money laundering is a crime that is most often associated with banking and money remittance services. Whilst banks are often an essential part of successful laundering schemes, the financial and related services that Licensees offer are also vulnerable to abuse by money launderers.

AML COMPLIANCE

An individual employee shall be appointed as Chief Compliance Officer which will oversee PytExchange LLC’s AML program and be responsible for arranging audits. The designated AML Officer will head the AML Committee which will be made up of the Corporate Attorney and the company shareholders. With respect to the Policy, the AML Compliance Committee’s duties include, but are not limited to, the implementation of and updating the Policy as required; dissemination of information to officers, employees and appointed producers of PYTEXCHANGE LLC, training of officers, employees and appointed producers; monitoring the compliance of PYTEXCHANGE LLC operating units and appointed producers, while maintaining necessary and appropriate records, filing of Suspicious Activity Reports (SARs) when the need arises; as well as independent assessment of the suitability and enforceability of the Policy.

TRANSACTION SCREENING AND MONITORING

In line with the AML Policy, PytExchange LLC has internal AML/CFT program designed to match the risk profile of the customers’ transactions, Hence; A customer may have only more than one account with PYTEXCHANGE LLC. However, each of those accounts may have only one beneficiary/owner. Only the account beneficiary/owner may deposit or withdraw funds to or from the account. Funds may be deposited by Credit or Debit Card, Wire Transfer, CashU, Neteller, or the CM Debit card. Upon withdrawal of funds from the account, the funds will be sent to the same method by which they were deposited, or to a verified method owned by the account beneficiary/owner. The account beneficiary/owner must be the verified owner of any method used to deposit or withdraw funds from a customer account.

CUSTOMER IDENTIFICATION

The identity of every customer is to be verified and this should be done through the supply of specific customer identification details from every customer. Information required may include but not limited to;
  • Full Name
  • Permanent residential address
  • Date of birth
  • Place of birth
  • Nationality:
Primary identity documentation for identity must be obtained and retained on these clients. They must bear a photograph of the principal. Primary identity documentations acceptable are:
1. Current valid passports;
2. National Identity cards;
3. Current valid driving licenses;
In addition to this primary identity documentation, we must also obtain additional verification of identity information- secondary identity documentation. The following documentation is acceptable: 4. A recent utility bill (which is less than 3 months old);
5. A domestic passport (page with registration address).
PYTEXCHANGE LLC will document its verification, including all identifying information provided by the customer, the methods used and results of the verification, including but not limited to sign-off by the appointed producer of matching photo identification. All of the identification and verification information will then be compared with Office of Foreign Assets Control (OFAC) database.

MONITORING AND REPORTING OF SUSPICIOUS TRANSACTIONS/ACTIVITY

• All personnel must be diligent in monitoring for any unusual and potentially suspicious transactions/activity basing on the relevant criteria applicable in the jurisdiction of the United States.
• The reporting of suspicious transactions/activity must comply with the International laws/regulations

RECORD KEEPING

• Records must be kept of all documents obtained for the purpose of identification and all transaction data as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations of the country;
• All records must be kept for at least 5 years as required by law;

TRAINING

• Training on anti-money laundering will be provided to those new employees who work directly with customers and to those employees who work in other areas that may be exposed to money laundering and terrorist financing threats which includes; Identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering and internal policies to prevent money laundering. • Follow-up trainings must take place not less than once a year.

OUR COMMITMENT

We are committed to complying fully with all applicable laws and regulations relating to combating money laundering and any activity which facilitates the funding of terrorist or other criminal enterprises.
Adherence to this policy is absolutely fundamental for ensuring fully comply with applicable antimony laundering legislation. PYTEXCHANGE LLC is committed to examining its anti-money laundering strategies, goals and objectives on an ongoing basis and maintaining an effective AML Policy. PYTEXCHANGE is obliged to follow the 40+9 recommendations given by the FATF Financial Action Task Force. We are responsible for uncovering or reporting any activity that might constitute, indicate or raise suspicions of money laundering. To this end, we provide continuing education and training for all such persons.
PYTEXCHANGE LLC is required to comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self regulatory organizations and law enforcement officials. As required by the Act, PYTEXCHANGE LLC may supply information about former, current or prospective clients to such bodies.

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