Aladiex - Blockchain and Crypto Asset Exchange

AML Policy

Last updated: 14 April 2020

This Regulatory Compliance, Verification & Anti Money Laundering Policy (“AML Policy”) and any terms expressly incorporated herein form a part of AladiEx Group’s (collectively, AladiEx”, “we”, “us” or “our”) Term and Conditions (“Terms”).

The AML Policy and Terms shall apply to your access to and use of our websites, mobile applications and platform, including any of our services rendered, as provided by AladiEx and its affiliates as described in these Terms.

1. Compliance

1.1. In the event that your AladiEx Account (or any other account registered to or associated with you or your Account) is suspected of being in breach of any of the provision of the AML Policy (or any requirements of law or regulation in the relevant jurisdiction), you agree that we have the right to suspend your AladiEx Account and your access to any of AladiEx’s Platform(s), until a thorough investigation has taken place.

1.2. Should your AladiEx Account (or any other account registered to or associated with you or your Account) be proven to be in breach of any of such provisions (or any requirements of law or regulation in the relevant jurisdiction), you agree that we have the right and legal obligation to disclose all your personal and account information to the relevant authorities, as appropriate, close/suspend your AladiEx Account and/or, restrict your access to the any of AladiEx’s Platform and Services.

2. Verification

In furtherance of our AML Policy, we reserve the right to require you, or any of our Clients to provide additional information to AladiEx or undergo a background check prior to being authorized as a Client or at any point thereafter in accordance with applicable laws.

3. Applicable rules and regulations for transaction

3.1. All of our Services facilitated by AladiEx through our Platform shall be subject to all applicable laws and regulations. This includes but is not limited to, the Anti-Money laundering and Counter-Terrorist Financing (Financial institutions) laws or any other relevant law and regulations.

3.2. The Services are at all times subject to all legislative and regulatory changes or actions within the relevant jurisdictions.

3.3. Any change or action may adversely affect the use, transfer, exchange, and value of your cryptocurrencies and may result in AladiEx having to suspect suspend any or all Services at any time. AladiEx shall not be liable for such change or action at any time.

4. Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy

The AladiEx AML Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in the relevant jurisdiction and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

The AML Policy sets out the minimum standards which must be complied with by AladiEx and its employees, and they include:

4.1. Establishing and maintaining a Risk Based Approach (“RBA”) towards assessing and managing the money laundering and terrorist financing risks to the Group;

4.2. Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (“KYC”) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (“PEPs”) and their relatives or associates;

4.3. Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;

4.4. Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

4.5. Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;

4.6. The maintenance of appropriate records for the minimum prescribed periods;

4.7. Training and awareness for all relevant employees;

4.8. Provision of appropriate management information and reporting to senior management of the Group's compliance with the requirements; and

4.9. The appointment of a Compliance Officer (“CO”) of sufficient seniority, who have responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance

AladiEx may require its clients to provide additional information or documentation to fulfil our legal obligations and, where we deem appropriate, refuse any client or transaction that is suspected of being related to financial crime.