FLUIDCOINS INC. AML/CFT POLICIES
Fluidcoins Inc. (Fluidcoins) is committed to fighting money laundering and complying fully with anti-money laundering legislations. We understand that we have responsibilities to help fight the global battle against money laundering and our commitment will supersede all other privacy obligations contained in our policies. Money laundering is the process whereby the financial proceeds of a crime are disguised to give the impression of legitimate income. Often criminals target financial service providers through which they attempt to launder criminal proceeds without raising suspicion. As a means to combat money laundering and to counter-terrorist financing (CTF), most countries have implemented AML and CTF legislation which imposes obligations on financial service providers.
Accordingly, in order to comply with applicable AML/CTF legislations, Fluidcoins has implemented systems and controls that meet the standards applicable to regulated sectors such as banking. This decision reflects our desire to prevent money laundering and terrorist financing. Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.
Fluidcoins AML and CTF framework include establishing and maintaining a risk-based approach to Customer Due Diligence, including customer identification, verification, and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details and documents when opening a Fluidcoins Account. In certain circumstances, Fluidcoins may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs); establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate; maintaining appropriate KYC records for the minimum prescribed periods; providing training on the framework and raising awareness among all relevant employees; designing systems and controls to allow Fluidcoins to comply with all required sanction screening processes imposed by relevant regulatory authorities and to take measures to prevent transacting with individuals, companies, and countries appearing on these sanctions lists.
There is also an independent AML/CTF Compliance function at Fluidcoins which shall be executed and managed by a designated Compliance Officer, who will regularly update management and board of directors on all material issues.
Fluidcoins identifies and assesses the money laundering and terrorism financing risks that may be associated with its unique business, services, and customers. More specifically, Fluidcoins shall carry out a business-wide AML/CTF risk assessment on a regular basis, for the purpose of assessing the risks to which Fluidcoins is exposed as a result of the nature and complexity of its business; and assess the risks to which Fluidcoins is exposed as a result of entering a business relationship or carrying out a particular transaction, on a continuous basis.
Fluidcoins will identify and assess the money laundering and terrorism financing risks that may arise in relation to new products and business practices as well as new service delivery channels; the adoption of new technologies for both new and pre-existing products; and new AML regulations and how they impact new and existing products and services.
Fluidcoins shall ensure timely and accurate rendition of all AML/CFT returns as specified in the relevant Regulations/Act/Guidelines/Circulars that may be issued from time to time by various government authorities. We shall exercise due diligence in identifying and reporting suspicious transactions. Suspicious transactions shall include transactions that are structured to avoid reporting and record-keeping requirements; altered or false identification or inconsistent information or any transaction involving criminal activity; and any entity that belongs to a person or organization considered as a terrorist.
KNOW-YOUR-CUSTOMER (KYC) POLICIES
In order to establish and maintain a risk-based approach to customer due diligence, including customer identification, verification and KYC procedures, our customers are required to provide certain personal details when opening an Account and generate tokens, OTP and PIN for any withdrawal request. The nature, and extent, of what is required is guided by the customer’s deposit and withdrawal limits, account to be used and in some cases, the customer’s country of residence.In certain circumstances, Fluidcoins may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes.