Crypto Arbitrages approach to utilising your personal information for the purpose of anti-money laundering (AML) and know-your-customer (KYC) processes
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. In many cases, laundered funds are used to fund further crime or to finance terrorism. Sometimes both.
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. Although it is not always clear in some of our countries, where we have a presence, whether these obligations fall on cryptocurrency providers, these laws, together with guidance from regulators, applicable task forces and industry best practices, form the cornerstone of Crypto Arbitrages approach to AML and CTF.
As such, Crypto Arbitrage 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.
Key components of Crypto Arbitrages's AML and CTF framework include the following:
- The appointment of a Money Laundering Reporting Officer (MLRO). This is an individual with a sufficient level of seniority and independence who is tasked with the responsibility of overseeing compliance with the relevant legislation, regulations, rules and industry guidance;
- The appointment of an independent risk committee that reports to our board of directors regularly on all risk and compliance matters;
- Establishing and maintaining a risk-based approach to the assessment and management of money laundering and terrorist financing risks;
- Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), 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 Crypto Arbitrage Account. The nature and extent of what is required are guided by the customer’s deposit and withdrawal limits and, in some cases, the customer’s country of residence. In certain circumstances, we may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs);
- Establishing and maintaining risk-based systems and procedures for the monitoring of ongoing customer activity;
- 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;
- Implementing a “travel-rule” framework, where this is required, to facilitate the exchange of customer information between cryptoasset service providers when sending and receiving cryptocurrency. The nature and extent of what is required is dependent on the sender and/or receiver’s country of residence;
- Designing systems and controls to allow Crypto Arbitrage to comply with all required sanction screening processes imposed by, for example, the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) and to take measures to prevent transacting with individuals, companies and countries appearing on these sanctions lists.
To achieve the above-defined objective, Crypto Arbitrage requests the following information when a client establishes a new account.
- Identification information: First and last name, date of birth, gender, phone number, email, government identification number (including tax identification, driver’s license number and passport number) and other information necessary to verify your identity to comply with our regulatory obligations under financial or anti-money laundering laws;
- Institutional information: If you are an institutional customer, we may collect your institution’s legal name, Employer Identification Number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), and personal identification information for all material beneficial owners;
- Financial information: Bank account information, routing number, transaction history, trading data and/or tax identification;
- Transaction information: Information about the transactions you make using our Services, such as the name of the recipient and the trading amount;
- Employment information: Your job title, office location or source of income; and
- Correspondence: Information you provide to our support teams.
Crypto Arbitrage only process and stores the minimum required information for the purposes of legally establishing a Crypto Arbitrage account - meaning that all required regulatory requirements are met. As a client you may request that your application or Crypto Arbitrage account be cancelled at any time, however, Crypto Arbitrage reserves the right to maintain your KYC records for the minimum prescribed periods as stipulated by your local authority.