CoinDepo AML/KYC Policy

Last modified: July 2022

1. Introduction

CoinDepo LLC (hereinafter “the CoinDepo”, “we”, “us” and/or “our(s)”) Anti-Money Laundering and Know Your Customer Policy (hereinafter “AML/KYC Policy”) is designed to prevent and mitigate possible risks of the CoinDepo being involved in any kind of illegal activity.

This document is a short extract of key principles from CoinDepo internal policy and should not be viewed as a full AML/KYC Policy.

Domestic and international regulations require the CoinDepo to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity.

This AML/KYC Policy covers the following matters:

• appointing an Anti-Money Laundering Compliance Officers (AMLCO) and making sure that employees know how to report any suspicious activity to them;

• identifying the responsibilities of senior managers and providing them with regular information on money laundering risks;

• training employees on their anti-money laundering responsibilities;

• documenting and updating anti-money laundering policies, controls and procedures;

• introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day business operations;

• forwarding/reporting all sustained suspicions to the appropriate authority;

• promptly responding to all communication from the appropriate authority.

2. Anti-Money Laundering Compliance Officer

The Anti-Money Laundering Compliance Officer (hereinafter “AMLCO” or “the Compliance Officer”) is ultimately responsible for implementing regulations concerning Anti-Money Laundering.

As noted above, the AMLCO is a person of authority with access to any and all relevant information for the performance of their duties.

You can contact CoinDepo AMLCO department by emailing us at: [email protected]

3. General Requirements for CoinDepo

Before the CoinDepo can execute any transaction for any new user, a number of procedures need to be in place and carried out:

• AML procedures, including user identification, record-keeping, discovering and monitoring of unusual or suspicious transactions and, as appropriate, internal/external reporting and control;

• ensuring that all employees know and understand their responsibilities and AML procedures;

• ensuring that appropriate training is undertaken;

• all relevant requests from outside sources should be forwarded directly to the AMLCO.

4. Identity Verification

Whenever the CoinDepo requests and receives supporting documents related to a new user’s identity, we must be completely satisfied that they demonstrate the existence of the new user as a real natural or legal person and that the user is indeed who they say they are.

User’s identification information will be collected, securely stored, shared and protected strictly in accordance with CoinDepo Privacy Policy and related regulations that correspond to the GDPR requirements, if necessary.

5. Transaction Monitoring

The constant monitoring of the users’ accounts and transactions is an imperative element in effectively controlling the risk of money laundering and terrorist financing. In this respect, the AMLCO shall be responsible for maintaining as well as developing the on-going monitoring process of CoinDepo.

6. Risk Assessment

We will apply appropriate measures and procedures by adopting a risk-based approach, so as to focus its efforts in those areas where the risk of money laundering and terrorist financing appears to be comparatively higher.

Further, the AMLCO shall monitor and evaluate the effectiveness of the measures and procedures of the AML/KYC Policy on an on-going basis.

The adopted risk-based approach that is followed by CoinDepo and described in the full AML/KYC Policy has the following general characteristics:

• recognizes that money laundering and terrorist financing threat varies across users, countries, services and financial instruments;

• allows to differentiate between users in a way that matches the risk of their particular business;

• allows to apply its own approach in formulation of policies, procedures and controls in response to particular circumstances and characteristics;

• helps to produce a more cost-effective and efficient system;

• promotes prioritization of effort and actions of the CoinDepo in response to the likelihood of money laundering and terrorist financing occurring through the use of our services.

The risk-based approach adopted by the CoinDepo, and described in this AML/KYC Policy, involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the money laundering and terrorist financing risks faced by the CoinDepo.

7. Sanctions

The CoinDepo does not carry out transactions with individuals and legal entities from countries under international sanctions, as well as from some other restricted jurisdictions.

We will therefore screen all new and existing users against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

The CoinDepo does not provide services to individuals and legal entities that are residents of the following jurisdictions:

• USA

• Afghanistan

• Burundi

• Central African Republic

• Congo

• Guinea

• Guinea-Bissau

• Haiti

• Iraq

• Mali

• Myanmar 

• North Korea

• Somalia

• South Sudan

• Sudan

• Syria

• Yemen

• Zimbabwe

The above list may be updated at any time with or without updating this AML/KYC Policy by a decision of the Compliance Officer.