KYC/AML Policy | 25 July 2018
TrigonX in accordance with the relevant provisions under AUSTRAC, are committed to actively preventing money laundering and terrorism financing. Our compliance team have established an AML/CTF policy that aims to reasonably identify, mitigate and manage the risks we face with respect to our Over the Counter ‘OTC’ trading company.
Our Core AML/CTF Principles
Provided below is an outline of Trigon Trading’s core principles with respect to AML/CTF:
- We are fundamentally opposed to all crimes associated with ML/TF and will not tolerate our OTC Trading Desk to be misused by offenders.
- We will ensure that we meet our AML/CTF regulatory obligations as a registered Digital Currency Exchange.
- We will ensure that our staff are appropriately educated and trained on AML/CTF issues.
- We will protect our company from any reputational damage associated with non-compliance as a Digital Currency Exchange.
- We have established and maintained a AML/CTF program that aims to reasonably identify, mitigate and manage associated risks.
- In the event an employee of Trigon Trading detects any suspicious matter or activity that falls within scope of Chapter 41 of the AML/CTF Act – we will report such suspicion to the relevant AUSTRAC authority.
- We will monitor our customers and users in a manner consistent with the respective level of risk they pose.
- We will strive to work with AUSTRAC on an ongoing basis to meet their expectations for the betterment of the digital economy.
With respect to Part A (general) and Part B (customer identification) – our AML/CTF Program aims to do the following.
- Comply as a Digital Currency Exchange under the AML/CTF laws and regulations in Australia.
- Give sufficient resources to the establishment and implementation of an effective AML/CTF program.
- Provide our OTC services only for customers who have successfully on-boarded through our KYC/AML form.
- Reasonably identify our customers and monitor their transactional behaviours to be able to classify their respective ML/TF risk.
- Educate our entire team & staff about all risks associated with ML/TF and what the relevant procedures are to combat such conduct.
- Update our AML/CTF program on an ongoing basis to ensure any product or service changes and their corresponding risks are amended accordingly.
The appointed AML Compliance Officer is responsible for the implementation of our AML/CTF Program. Our Program has been reviewed and approved by all senior management. All relevant directors will remain responsible for the oversight and successful implementation of our Program on a day to day basis.
Please contact our AML Compliance Officer at email@example.com