Anti-Money Laundering (AML) Policy

1. Introduction and Commitment

WalletConvert, is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our approach to detecting, preventing, and reporting money laundering and terrorist financing activities.

We maintain a zero-tolerance policy towards money laundering and terrorist financing. All employees, partners, and service providers must adhere to this policy and applicable AML/CTF regulations.

2. Regulatory Framework

Our AML/CTF program complies with:

• Financial Intelligence Centre Act (FICA) of South Africa
• Financial Action Task Force (FATF) Recommendations
• Local AML/CTF regulations in all countries where we operate
• International sanctions programs (UN, EU, US OFAC)

3. AML Compliance Officer

Our AML Compliance Officer is responsible for implementing and maintaining this policy, conducting risk assessments, and serving as the primary contact for regulatory authorities.

4. Customer Due Diligence (CDD)

4.1 Identity Verification

We conduct thorough Know Your Customer (KYC) procedures for all users, including:

• Collection of government-issued identification
• Verification of identity through automated systems
• Facial recognition matching
• Address verification
• Source of funds verification for high-value transactions

4.2 Enhanced Due Diligence (EDD)

We apply enhanced due diligence for:

• Politically Exposed Persons (PEPs)
• High-risk jurisdictions
• Complex or unusual transactions
• Transactions exceeding $10,000 USD equivalent

4.3 Ongoing Monitoring

We continuously monitor customer accounts for:

• Unusual transaction patterns
• Changes in transaction behavior
• Transactions inconsistent with customer profile
• Multiple accounts or structured transactions

5. Risk Assessment

We conduct regular risk assessments considering:

• Customer Risk: Type of customer, occupation, transaction patterns
• Geographic Risk: Customer location, transaction destinations
• Product Risk: Types of cryptocurrencies, transaction methods
• Channel Risk: Online platform vulnerabilities

Risk Categories

Customers are classified into risk categories:

• Low Risk: Standard KYC procedures
• Medium Risk: Enhanced monitoring
• High Risk: Enhanced due diligence and approval required

6. Transaction Monitoring

Our automated systems monitor for suspicious activities including:

• Rapid movement of funds
• Transactions just below reporting thresholds
• Multiple transactions to avoid limits (structuring)
• Transactions with high-risk jurisdictions
• Unusual patterns or volumes
• Transactions inconsistent with stated purpose

7. Sanctions Screening

We screen all customers and transactions against:

• United Nations Security Council Sanctions Lists
• US Office of Foreign Assets Control (OFAC) lists
• European Union Consolidated Sanctions List
• Local sanctions lists in operating countries
• Politically Exposed Persons (PEP) databases

Screening is conducted at account opening and on an ongoing basis. Any matches result in immediate escalation and potential account restrictions.

8. Reporting Obligations

8.1 Suspicious Activity Reports (SARs)

We file SARs with relevant Financial Intelligence Units when we detect:

• Suspected money laundering activities
• Terrorist financing indicators
• Transactions with no apparent lawful purpose
• Attempts to avoid reporting requirements
• Use of false identification

8.2 Currency Transaction Reports (CTRs)

We report transactions exceeding regulatory thresholds in accordance with local requirements.

8.3 Confidentiality

Filing of SARs is strictly confidential. Tipping off customers about investigations or reports is prohibited and may result in criminal penalties.

9. Record Keeping

We maintain records for a minimum of 5 years (or as required by local law) including:

• Customer identification documents
• Transaction records
• Account opening documents
• Correspondence with customers
• Internal reports and analysis
• SAR filings and related documentation

10. Training and Awareness

All employees receive AML/CTF training covering:

• Recognition of money laundering and terrorist financing
• Internal policies and procedures
• Reporting obligations and procedures
• Customer due diligence requirements
• Sanctions screening procedures
• Handling of suspicious activities

Training is conducted upon hiring and annually thereafter, with additional training as regulations change.

11. Prohibited Activities

The following activities are strictly prohibited:

• Processing transactions for sanctioned individuals or entities
• Facilitating transactions designed to evade reporting requirements
• Accepting funds from unknown or unverified sources
• Processing transactions involving illegal activities
• Mixing or tumbling services
• Anonymous or privacy-enhanced cryptocurrency transactions

12. Account Restrictions and Termination

We may restrict or terminate accounts for:

• Failure to complete KYC verification
• Suspected involvement in money laundering or terrorist financing
• Providing false or misleading information
• Violation of this AML policy
• Appearance on sanctions lists
• Refusal to provide requested information

13. Customer Obligations

Customers must:

• Provide accurate and complete information
• Update information when changes occur
• Cooperate with verification procedures
• Provide source of funds documentation when requested
• Not use our services for illegal purposes
• Report any unauthorized account activity immediately

14. Cooperation with Authorities

We maintain full cooperation with law enforcement and regulatory authorities including:

• Responding to subpoenas and court orders
• Providing information for investigations
• Freezing accounts when legally required
• Reporting suspicious activities
• Participating in regulatory examinations

15. Internal Controls and Audit

Our AML program includes:

• Regular internal audits of AML procedures
• Independent testing of systems and controls
• Management oversight and accountability
• Continuous improvement processes
• Technology solutions for monitoring and detection

16. Consequences of Non-Compliance

Failure to comply with AML/CTF regulations may result in:

• Significant financial penalties
• Criminal prosecution
• Loss of operating licenses
• Reputational damage
• Civil liability

All employees are required to report any suspected violations of this policy immediately.

17. Updates to This Policy

This AML Policy is reviewed annually and updated as necessary to reflect:

• Changes in regulations
• Emerging risks and typologies
• Operational changes
• Industry best practices
• Regulatory guidance and feedback

18. Contact Information

For questions regarding this AML Policy or to report suspicious activities:

19. Acknowledgment

By using WalletConvert services, you acknowledge that you have read, understood, and agree to comply with this Anti-Money Laundering Policy. You understand that violation of this policy may result in immediate account termination and reporting to relevant authorities.