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AML Policy

Anti-Money Laundering (AML) Policy

Overview

Exchangerland, and Exchangerland.com (collectively referred to as the “Organization”), established under Delaware state law, operates a digital platform and facilitates peer-to-peer (P2P) transactions for buying and selling cryptocurrencies and other digital assets. The Organization is committed to preventing illegal activities on its platform and safeguarding its users, operations, and the broader cryptocurrency ecosystem from criminal exploitation.

Regulatory Compliance

Registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department, the Organization adheres to the Bank Secrecy Act (BSA) and complies with all applicable FinCEN regulations and guidelines.

Know Your Customer (KYC) Program

To ensure the legitimacy of its users, the Organization has implemented comprehensive KYC procedures for both individual and institutional clients. These measures allow the Organization to verify the true identity of its users, applying to all platform participants, including employees, contractors, executives, and board members.

AML and Compliance Measures

The Organization employs a risk-based approach to AML and compliance, incorporating the following strategies:

  • Ongoing Transaction Monitoring: Continuous rule-based monitoring to detect irregular activities.
  • Blockchain Analytics: Conducting investigations using advanced blockchain analysis tools.
  • Suspicious Activities Reporting (SARs): Filing SARs when suspicious activities are identified, such as transactions inconsistent with a user’s known financial profile or legitimate activities.
  • Anti-Fraud Systems: Using multiple systems to detect and prevent fraudulent activities.
  • Sanctions Compliance: Adhering to Office of Foreign Assets Control (OFAC) regulations, including compliance with Specially Designated Nationals (SDN) and Blocked Persons lists.
  • Risk-Based Verification Tiers: Implementing tiered verification processes based on user risk profiles.
  • Regulatory Cooperation: Collaborating with law enforcement and adhering to local regulatory requirements.
  • Compliance Training: Providing organization-wide training on BSA, AML, and OFAC compliance.
  • Chief Compliance Officer: Appointing a qualified and independent Chief Compliance Officer to oversee compliance with relevant laws, regulations, and industry standards.

Suspicious Activity Reporting

The Organization files SARs when there is knowledge, suspicion, or reason to suspect illicit activities on the platform. The Chief Compliance Officer evaluates suspicious activities, ensuring sufficient evidence is gathered before filing a SAR and maintaining detailed records of all filings.

Sanction Policy

The organization enforces strict policies to prevent transactions involving sanctioned individuals, entities, or jurisdictions, as outlined by OFAC. Users from high-risk or banned countries are restricted from accessing the platform. For accounts frozen due to sanctions violations, users may apply for an OFAC license via the provided link.

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

The Organization maintains risk-based CDD and EDD policies to thoroughly assess user identities and activities, ensuring compliance with regulatory standards and mitigating risks.

Translation Disclaimer

If a translated version of this policy is provided, it is for convenience only. The English version of the policy governs all interactions with the Organization. In case of discrepancies between the English version and any translation, the English version prevails.

 

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