CRYPTOSAVER ANTI MONEY LAUNDERING (“AML”) AND COUNTER TERRORIST FINANCING (“CTF”) POLICY
Money laundering involves hiding, disguising or legitimising the true origin and ownership of money used in or derived from committing crimes. Money launderers often use financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions.
In response to the scale and effect of money laundering in both New Zealand and Australia the respective governing bodies have implemented a strong regime to fight money laundering and terrorism financing. Cryptosaver Pty Ltd is currently regulated within the scope of the AML/CTF obligations in New Zealand and Australia. The senior management have implemented systems and procedures that meet the strictest AML legislation that apply to our business. This decision reflects the senior managements desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
NZ & AUS AML LEGAL AND REGULATORY FRAMEWORK
The New Zealand AML regime is set out in the following legislation:
- Anti-money laundering and Countering Financing of Terrorism Act 2009
The Australian AML regime is set out in the following legislation:
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006
ANTI-MONEY LAUNDERING (AML) POLICY
The Cryptosaver AML Policy is designed to prevent money laundering by meeting the NZ & AUS AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
- Enrolment of the Australian business with AUSTRAC
- Establishing and maintaining an AML/CTF program to help identify, mitigate and manage the money laundering and terrorism financing risks a business faces. Cryptosaver limited will maintain a Risk-Based Approached (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company
- The appointment of an AML/CTF compliance officer who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
- An ML/TF risk assessment of the business is conducted and reviewed periodically by the business and also subject to regular independent review
- Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced customer due diligence (ECDD) for those customers presenting higher risk, such as Politically Exposed Persons (PEPs); Cryptosaver Pty Ltd uses an Australian and New Zealand Government approved verification system called Green ID to verify our customers.
- Ongoing customer due diligence procedures (OCDD) and reporting (suspicious matters, threshold transactions and international funds transfer instructions).
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- The maintenance of appropriate records for the minimum prescribed periods;
- AML/CFT compliance training and awareness for all employees
- An employee due diligence for screening staff members to minimise any exposure to risk
Cryptosaver Pty Ltd is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Cryptosaver Pty Ltd will therefore use the sanction screening services provided by Government approved Green ID in order to ensure all users are checked against international watch lists.
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