AML/KYC Policy

1. Introduction and Regulatory Framework

CryptoElite Pro Limited is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our comprehensive AML/KYC framework in compliance with:

UK Regulations

• Money Laundering Regulations 2017
• Proceeds of Crime Act 2002
• Terrorism Act 2000
• FCA Handbook (SYSC, CASS)
• Economic Crime Act 2023

International Standards

• FATF Recommendations
• EU 5th Anti-Money Laundering Directive
• UN Security Council Resolutions
• OFAC Sanctions Programs
• Basel AML Index Guidelines

Professional Clients Only: Our enhanced AML/KYC procedures are designed for institutional and high-net-worth professional clients.

2. Risk Assessment Framework

We conduct comprehensive risk assessments considering multiple factors:

Customer Risk

• PEP status and associations
• Geographic risk factors
• Business type and structure
• Source of funds complexity
• Historical compliance issues

Product Risk

• Cryptocurrency anonymity features
• Transaction size and frequency
• Cross-border movements
• DeFi protocol interactions
• Privacy coin exposure

Delivery Channel Risk

• Remote onboarding procedures
• Digital identity verification
• API and automated access
• Third-party integrations
• Mobile and web platforms

3. Know Your Customer (KYC) Procedures

Standard KYC Requirements

Individual Clients

• Government-issued photo ID
• Proof of address (utility bill, bank statement)
• Source of wealth documentation
• Professional credentials/qualifications
• Investment experience questionnaire
• Risk tolerance assessment

Corporate Clients

• Certificate of incorporation
• Memorandum and articles
• Beneficial ownership register
• Board resolutions and authorized signatories
• Audited financial statements
• Regulatory licenses (where applicable)

Enhanced Due Diligence (EDD)

Required for high-risk clients, including PEPs, clients from high-risk jurisdictions, or complex ownership structures:

• Source of funds verification
• Source of wealth documentation
• Business purpose and nature
• Expected transaction patterns
• Reputation and background checks

• Adverse media screening
• Sanctions and PEP screening
• Country risk assessment
• Enhanced ongoing monitoring
• Senior management approval

4. Ongoing Monitoring and Surveillance

Transaction Monitoring

We employ sophisticated transaction monitoring systems that analyze:

• Transaction amounts and frequencies
• Geographic patterns and anomalies
• Counterparty risk indicators
• Velocity and timing analysis
• Cross-reference with sanctions lists
• Blockchain analytics and tracing

Periodic Reviews

Low Risk

Annual review of client information and risk profile

Medium Risk

Semi-annual review with enhanced documentation

High Risk

Quarterly review with comprehensive assessment

5. Sanctions and PEP Screening

Comprehensive Screening Program

We screen all clients, beneficial owners, and transaction counterparties against:

Sanctions Lists

• OFAC (US Treasury)
• UN Security Council
• EU Consolidated List
• UK HM Treasury
• Other relevant jurisdictions

PEP and Risk Databases

• Politically Exposed Persons (PEPs)
• Relatives and Close Associates (RCAs)
• Adverse media and news
• Law enforcement databases
• Financial intelligence databases

Screening is performed at onboarding, periodically during the relationship, and in real-time for transactions.

6. Suspicious Activity Reporting (SAR)

Red Flag Indicators

We monitor for suspicious activities including:

• Unusual transaction patterns or amounts
• Rapid movement of funds
• Transactions with high-risk jurisdictions
• Structuring to avoid reporting thresholds
• Use of multiple accounts or entities

• Inconsistent with client profile
• Links to criminal or sanctioned entities
• Mixing services or privacy coins
• Reluctance to provide information
• Unusual geographic transaction patterns

Reporting Process

When suspicious activity is identified:

Immediate escalation to MLRO
Investigation and documentation
Decision on filing SAR to NCA
Submission within required timeframes
Ongoing monitoring of reported activity
Consideration of relationship termination

7. Record Keeping and Data Retention

AML/KYC Records

We maintain comprehensive records for the periods required by law:

• Customer identification records: 5 years after relationship ends
• Transaction records: 5 years after completion
• Suspicious activity reports: 5 years after filing
• Risk assessments and reviews: 5 years after update
• Training records: 5 years after completion

Data Security

AML/KYC records are protected with enhanced security measures including encryption, access controls, audit trails, and secure disposal procedures.

8. Training and Governance

Staff Training

• Mandatory AML/KYC training for all staff
• Role-specific compliance training
• Regular updates on regulatory changes
• Scenario-based testing and assessment
• Annual recertification requirements

Governance Structure

• Board oversight and approval
• Money Laundering Reporting Officer (MLRO)
• Compliance Committee
• Independent compliance monitoring
• Annual policy review and updates

9. Consequences of Non-Compliance

Zero Tolerance Policy

Failure to comply with our AML/KYC requirements may result in:

• Immediate account suspension or closure
• Freezing of funds pending investigation
• Reporting to regulatory authorities
• Termination of business relationship
• Cooperation with law enforcement
• Legal action for recovery of costs

We reserve the right to refuse service to any individual or entity that fails to meet our compliance standards.

10. Compliance Contacts

AML/KYC Queries

MLRO: Sarah Johnson, CAMS
Email: [email protected]
Compliance Team: [email protected]
Phone: +44 207 123 4567

Regulatory Information

FCA Reference: FRN-ELITE-789456
MLR Registration: 12345678
Verify License: FCA Register
NCA Reporting: Via UKFIU portal

Regulated Entity Information

Company Details

Compliance Officer