AML

Anti-Money Laundering Policy

Last updated December 1, 2024

2. Definitions

1. Money Laundering: The process of making illegally obtained funds appear legitimate

2. Criminal Activity: Any activity that involves the acquisition, transfer, or use of funds generated through illegal means.

3. Customer: Any individual or entity using Apexpay's platform for cryptocurrency transactions

3. Compliance Officer

Apexpay appoints a Compliance Officer responsible for overseeing the company's AML program, ensuring compliance with all relevant AML laws and regulations. The Compliance Officer will:

  1. Regularly review and update the AML policy.
  2. Monitor transactions for suspicious activities.
  3. Report suspicious activities to the appropriate authorities.

4. Customer Due Diligence (CDD)

Apexpay will conduct thorough Customer Due Diligence for all customers. This includes:

  1. Collecting and verifying customer identification information.
  2. Assessing the risk level associated with each customer.
  3. Conducting ongoing monitoring of customer accounts.

5. Enhanced Due Diligence (EDD)

For customers with higher risk profiles, such as those conducting large transactions, Apexpay may implement Enhanced Due Diligence measures, which may include additional identity verification and transaction monitoring.

6. Reporting Suspicious Activities

Apexpay will promptly report any suspicious activities to the relevant authorities in accordance with applicable AML regulations.

7. Record Keeping

Apexpay will maintain accurate records of all customer transactions, including identification documents and transaction history, for a minimum period as required by applicable laws and regulations.

8. Training and Awareness

Apexpay will provide ongoing AML training to employees to ensure they are aware of their responsibilities and can identify suspicious activities. Employees will be required to report any suspicious transactions promptly.

9. AML Risk Assessment

Apexpay will regularly assess and update its AML risk assessment to account for changing regulatory requirements and emerging risks associated with money laundering

9. Independent Review

An independent review of our AML program will be conducted periodically to ensure its effectiveness and compliance with regulations

11. Policy Updates

This AML policy will be reviewed and updated as necessary to reflect changes in AML laws, regulations, and business operations.

12. Conclusion

Apexpay is dedicated to maintaining a secure and compliant platform for cryptocurrency trading. We are committed to preventing money laundering activities and will take all necessary steps to ensure the integrity of our platform and the safety of our users.