Anti-Money Laundering (AML) Policy for Digifolio Investments Limited
Introduction:
Digifolio Investments Limited has established an AML Policy, which outlines the actions, procedures, and controls in place to prevent and detect money laundering, terrorist financing,
and illicit activities within the cryptocurrency investment sector. The company is dedicated to adhering to all relevant laws and regulations pertaining to AML and will take appropriate measures to mitigate financial crime risks.
Policy Statement:
Digifolio Investments Limited is committed to maintaining a robust AML program that encompasses thorough due diligence processes, risk assessment, customer identification, transaction monitoring,
reporting of suspicious activities, and continuous training. This policy applies to all individuals involved in Digifolio Investments Limited’s operations, including employees, contractors, and stakeholders.
Risk Assessment:
Digifolio Investments Limited will conduct a comprehensive risk evaluation to identify and comprehend potential money laundering and terrorist financing risks associated with its operations, clients, services,
and geographical areas. The risk assessment will be regularly reviewed and updated for relevance.
Customer Due Diligence (CDD):
Customer Identification: Digifolio Investments Limited will verify the identity of all clients through reliable and independent sources, with enhanced due diligence (EDD) applied to high-risk clients.
Beneficial Ownership:
Digifolio Investments Limited will identify and authenticate the beneficial owners of legal entities, trusts, and complex structures.
Transaction Monitoring:
Digifolio Investments Limited has implemented a system that includes AMLBOT to scrutinize transactions for unusual or suspicious activities. Thresholds for monitoring will be established,
and alerts will be assessed by designated personnel. If a deposit is found to have originated from sources such as Dark Market, Dark Services, Illegal Services, Stolen, Gambling, or Scam,
Digifolio Investments Limited reserves the right to withhold the funds with a 10% penalty within a 30-day period. Tags for reference: Darknet Marketplace, Darknet Service, Illegal Service, Scam, Stolen Coins,
Terrorism financing, Child exploitation, Enforcement Action, Exchange Fraudulent, Gambling, Mixer, Ransom, Sanctions.
Suspicious Activity Reporting:
Employees who suspect any transaction or activity to be associated with money laundering, terrorist financing, or other criminal activities must report it to the designated AML officer. The AML officer will assess the report and,
if necessary, submit a Suspicious Activity Report (SAR) to relevant authorities.
Record Keeping:
Digifolio Investments Limited will maintain accurate and current records of client identification, transaction history, expected persistence, and SARs, securely stored for the required duration as per regulations.
Employee Training:
All employees will undergo regular AML training to stay updated on AML regulations, criminal techniques, and company policies and procedures.
Compliance Officer:
Digifolio Investments Limited will appoint a dedicated AML compliance officer responsible for overseeing policy implementation, conducting internal audits, and ensuring compliance with AML regulations.
Third-Party Relationships:
When entering into business relationships with third parties, Digifolio Investments Limited will ensure adherence to AML standards and proper policies and procedures.
Sanctions Compliance:
Digifolio Investments Limited will screen clients against relevant sanctions lists and comply with economic and trade sanctions imposed by applicable jurisdictions.
Continuous Improvement:
Digifolio Investments Limited will regularly review and update its AML policy to adapt to regulatory changes, industry practices, and evolving cryptocurrency investment sector risks.
Communication and Reporting:
This policy will be communicated to all relevant stakeholders and reported to senior management and regulatory authorities as required.
Enforcement:
Non-compliance with this policy may result in disciplinary action, including termination of employment or contractual relationship, and legal consequences.
Rights Reserved:
Digifolio Investments Limited reserves the right to refuse deposits, request additional information regarding the source of digital assets, block user accounts, cooperate with law enforcement,
request identity documents, hold funds during investigations, and monitor transactions to identify suspicious activity.
List of Required and Supported Documents: During the verification process at DigiPool, the following documents may be required:
Government-issued International Passport
Government-issued Identity Card
Selfie with Identity Document
Utility bill or Bank Statement (not older than three months, no modifications allowed)
Conclusion:
This AML Policy reflects Digifolio’s commitment to combat financial crime in the cryptocurrency investment sector. Through these measures,
Digifolio Investments Limited aims to safeguard its reputation, integrity, and the financial system’s integrity as a whole.
Digifolio Investments Limited 25/05/2024