Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Last updated: November 6, 2020

DXOne Ltd (“DXone”) has an Anti-Money Laundering, Counter-Terrorist Financing and Know Your Customer Policy (“AML/KYC policy”) to maintain legal compliance with our obligation to identify, prevent and mitigate risks of activity not permitted by the law.

This AML/KYC policy is an integral part of the DXone Terms of Use (link) and should be read as part of the Law Enforcement Requests policy (link) and in accordance to our Privacy policy (link). The legal basis for this AML/KYC policy includes but is not limited to the European Union’s 5th Anti-Money Laundering Directive ((EU) 2018/843) and Cyprus’s Prevention and Suppression of Money Laundering Activities Law of 2007 (L188(I)/2007).

Risk Assessment

Following guidance from the Financial Action Task Force (FATF) an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction and Cyprus Securities and Exchange Commission (CySEC), DXone takes a risk-based approach to assess and mitigate risk.

Compliance Officer

DXone has appointed a compliance officer who is the point person to oversee all AML/KYC activity. This person is knowledgeable about financial crime regulations and laws, is the liaison for law enforcement officers, has developed our internal controls and tools and has conducted ongoing training for DXone staff. The contract information for this officer is [email protected].

Transactions Monitoring

Transaction monitoring helps DXone to follow transactions such as deposits, withdrawls, and trades 24/7 and in real time. The monitoring helps to undercover patterns or outlier activity and to monitor the level of risk that is associated with each user and their transactions. For example, transaction monitoring can flag a large withdrawal from the otherside of the world as suspicious, providing key information to aid law enforcement and the client. Transaction monitoring can reduce fraud and all money laundering. Transaction monitoring can also include daily blacklist or politically exposed persons (PEP) monitoring. DXone along with its partners complete a range of data analysis on transactions undertaken on the platform and their patterns. These steps include recording data, filtering, record-keeping, investigation management, and reporting. When needed, DXone may take additional steps, including but not limited to, request additional verification for users transactions, to place users on watch lists, or to file any reports such as a suspicious activity report (SAR) with the appropriate law enforcement authorities.

KYC verification

Know-Your-Customer (KYC) is the standard protocol against both in traditional financial services as well as the cryptocurrency industry. The DXone verification procedures are industry standard. In accordance with our partners, DXone will use documents and information provided by users to confirm the identity of all users on the platform. Users whose identity can not be confirmed may not be granted access to DXone and all users who are identified as dangerous or suspicious will be flagged. DXone reserves the right to require additional information on an ongoing basis to reverify users, particularly should users or their transactions suggest a higher than average risk. DXone reserves the right to refuse to provide its services to users for any reason and without explanation.

In Cyprus, this includes the Central Bank of Cyprus’ Directive (Fifth Edition) issued in accordance with Article 59(4) of the Prevention and Suppression of Money Laundering Activities Laws of 2007 to 2018 (“Law”). This Cyprus legislation and EU directives including the Fifth Money Laundering Directive (5AMLD) implemented on January 10th, 2020 are intended for the prevention of using the financial system including exchanges such as DXone money laundering and terrorist Financing.

Article 62(1) of the Law requires that the identification of the customer and the beneficial owner is performed prior to the establishment of the business relationship or the execution of a transaction. It is for this reason we provide the KYC at the start of your on-boarding. Article 61(1) of the Law requires that the customer identification procedures and due diligence measures, include the following: (i) the identification and the verification of the customer's identity on the basis of documents, data or information issued or obtained by a reliable and independent Source. To do so, we work with our KYC partners to verify that the person registering the account matches with the name and address of existing real persons who have not been convicted of financial crimes.

DXone does not currently accept fiat funds and thus is not subject to any specific requirement to trace the origins of those funds or any regulation which targets cryptocurrency platforms. Should DXone offer this feature in the future, these policies will change in accord with international and national regulations.

Changes to the AML/KYC

DXone reserves the right to revise this AML/KYC policy at any time and for any reason. The most current and recent version can be found at this page and with the date at the top. We expect our users to stay aware of these legally binding changes by watching this page. Certain elements of this AML/KYC policy may be superseded by changes in the law of our governing jurisdiction as well as by other notices found on this site.