The purposes of the EXOMOON Anti-Money Laundering, Counter-Terrorist Financing, and Know Your Client Policy (hereafter referred to as the "AML/CTF and KYC Policy") is to identify, prevent, and reduce the risks associated with illegal activities involving Exomoon SIA (hereinafter referred to as “Exomoon”, “we” and/or “us”).

In adherence to international and local regulations, Exomoon has established effective internal procedures aimed at preventing money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. These procedures are designed to efficiently identify and respond to any suspicious activities by its users (hereinafter referred to as “you”).

In this document, Exomoon outlines the risk assessment, verification process, and transaction monitoring procedures for users using Exomoon services on third-party P2P platforms and/or mobile applications. This document is an essential component of the Terms and Conditions governing the use of Exomoon services. Additionally, users are subject to the terms and conditions established by the third-party copyright holder of the P2P platform and/or mobile application.

Anti-money laundering (AML) refers to the laws, regulations, and procedures put in place to prevent criminals from concealing illegally obtained funds as lawful income.

Combating the Financing of Terrorism (CFT) is a collection of government laws, regulations, and practices designed to limit access to funding and financial services for individuals designated as terrorists by the government. By tracing the origin of funds that aid terrorist activities, law enforcement aims to potentially stop such activities from happening.

All firms must comply with regulations regarding Money Laundering, Terrorist Financing, and follow the recommendations outlined by the Financial Action Task Force (FATF). The FATF is an inter-governmental organization focused on developing and advocating for both national and international policies aimed at combating money laundering and terrorist financing.

AML/CFT and KYC Policy includes:

• Verification Procedure;
• The Compliance Person;
• Transactions Monitoring;
• Risk Assessment;
• Risk categories.

VERIFICATION PROCEDURE

To combat terrorism funding and money laundering, financial institutions are mandated by law to collect, verify, and document identifying information for every individual or entity opening an account. We are obligated by law to request details like your name, address, date of birth, and other pertinent information about you or your organization. Additionally, we may require certain identification documents such as your driver’s license, passport, or your organization’s articles of incorporation. We may also access credit and consumer reports to verify your identity and determine if you meet our account criteria. Unless you provide the requested information and documentation, we may not be able to provide services to you.

By starting an exchange with Exomoon, you agree to provide the information and documentation requested by Exomoon and consent to Exomoon acquisition of credit and other consumer reports about you for the purposes described above.

The Exomoon User due diligence (“CDD”) procedure requires Users to provide Exomoon with dependable, independent source documents to establish their identity and verify their residential address. These documents may include a national ID card, an international passport, a bank statement, or a utility bill. Exomoon reserves the right to gather Users’ identification information for compliance with its AML/CFT and KYC Policy.

Exomoon will verify the authenticity of documents and information provided by Users. Additionally, Exomoon will seek to confirm identification details through secondary sources and retains the right to conduct further investigations in cases where the documentation submitted is deemed unsatisfactory.

Exomoon retains the right to periodically verify the user's identity, particularly in instances where there have been changes to their identification details or if their activities raise suspicions. Moreover, Exomoon may request updated documents from users, even if their authenticity has been previously confirmed.

Details regarding the user's identification will be gathered, stored, shared, and safeguarded in strict compliance with the Exomoon Privacy Policy and pertinent regulations. The user consents that if any information provided in the KYC application changes, becomes untrue, or is significantly misleading (including, but not limited to, changes in contact information), they will promptly inform Exomoon of these modifications.

After confirming the user's identity, Exomoon may decline to provide services to the user if there are suspicions that Exomoon's services are being used for illegal activities.

Exomoon is obligated by regulations to verify the origins of Fiat Money and/or Cryptocurrency to ensure the legitimacy of the funds used by Users for trading. To fulfill this requirement, Exomoon may request evidence of the fund's source, which could involve providing bank statements for Fiat Money or presenting a video demonstrating wallet transaction details for Cryptocurrency.

Exomoon uses independent third-party companies for the following:

• check Users against Politically Exposed Person’s (PEP) and Sanctions Lists;
• assess User’s cryptocurrency wallets with regards to AML investigation and compliance.

Exomoon reserves the right to refuse services to users based on information obtained from third-party entities, which encompasses users associated with "high-risk" wallets.

THE COMPLIANCE PERSON

The Compliance Person, authorised by Exomoon, is tasked with ensuring the effective implementation and enforcement of the AML/CFT and KYC Policy. Their responsibility encompasses overseeing all aspects of Exomoon's anti-money laundering and counter-terrorist financing procedures:

• collection of Users’ identification information;
• establishing and updating internal policies and procedures pertaining to the completion, review, submission, and retention of all reports and records mandated by relevant laws and regulations;
• monitoring transactions and investigating any significant deviations from normal activity;
• implementing a records management system to ensure the appropriate storage and retrieval of documents, files, forms, and logs, updating risk assessments regularly and providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Person serves as the primary contact for Exomoon with law enforcement agencies to address matters related to the prevention of money laundering, terrorist financing, and other illegal activities.

TRANSACTION MONITORING

Before engaging in trading, Exomoon users are required to undergo the Exomoon identity verification process to confirm their identity. Upon completion of the verification process, users agree to transaction monitoring, where Exomoon assesses users' transactional behaviors and patterns.

Exomoon depends on data analysis tools for risk assessment and detecting suspicious activities. These tools perform various compliance-related tasks such as capturing data, filtering, record-keeping, managing investigations, and reporting.

In connection with the AML/CFT and KYC Policy, Exomoon will:

• monitor all transactions. Exomoon retains the right to report transactions of suspicious nature to the appropriate law enforcement authorities;
• in case of suspicious transactions, Exomoon may request the user to provide additional information and documents;
• Exomoon may suspend or terminate work with a client if there is a reasonable suspicion that the client is engaged in illegal activities.

However, the list provided above is not exhaustive, and the Compliance Person will regularly monitor users' transactions to determine whether such activities should be flagged and treated as suspicious.

RISK ASSESSMENT

The European Union has implemented comprehensive legislation aimed at combating money laundering and terrorist financing, which significantly contributes to global efforts in this regard. The Commission ensures the effective implementation of this legislation by assessing the incorporation of EU directives into national laws and collaborating with networks of competent authorities.

The Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) continuously evaluates adherence to the primary international standards for combating money laundering and terrorist financing, as well as the effectiveness of their implementation. Additionally, MONEYVAL provides recommendations to national authorities regarding essential enhancements to their systems and conducts thematic typology research on money laundering and terrorist financing.

The FATF consistently monitors new techniques used by criminals to launder illegal proceeds and investigates how terrorists obtain, use, and transfer the necessary funds. FATF typologies reports aim to raise awareness with authorities as well as the private sector about the risk of particular sectors or products, so that they can take appropriate actions to mitigate these risks.

To meet its obligations regarding Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF), Exomoon conducts an annual AML Risk Assessment. The aim of this assessment is to prevent criminals from exploiting Exomoon for money laundering by identifying risks and evaluating the controls implemented by Exomoon. A risk-based methodology is employed to identify Users and access their usage of our Services.

The Compliance Person is tasked with overseeing financial crime risks and enhancing financial crime risk management by identifying both general and specific money laundering risks encountered by Exomoon. They assess how these risks are addressed by Exomoon's AML controls and determine the residual risk that remains for the company.

RISK CATEGORIES:

RISK BY USERS:

Suspicious indicators may include, but are not limited to: inconsistencies in provided identification documents, fictitious identities, stolen or counterfeit identification documents, the use of post box addresses as residential addresses, a history of previous financial crimes, terrorist affiliations, being wanted by authorities, lack of a valid contact phone number, and discrepancies in documents provided for legal entities, etc.

Politically exposed persons (PEPs) include, but are not limited to, individuals holding prominent public positions such as heads of state, heads of government, ministers and their deputies or assistants, members of parliament or similar legislative bodies, members of governing bodies of political parties, members of supreme courts or courts of auditors, members of central bank boards, ambassadors, chargés d'affaires, high-ranking officers in the armed forces, members of administrative, management, or supervisory bodies of state-owned enterprises, and directors, deputy directors, and board members or equivalent roles in international organizations, excluding middle-ranking or junior officials.

RISK BY COUNTRIES:

EU policy regarding high-risk third countries, as outlined in Directive (EU) 2015/849, Article 9, mandates the Commission to identify third countries deemed to have strategic deficiencies in their anti-money laundering and counter-terrorism financing regimes. This aims to safeguard the integrity of the EU financial system.

The 5th Anti-Money Laundering Directive ((EU) 2018/843) imposes more stringent due diligence requirements for business relationships or transactions involving high-risk third countries. These requirements entail obtaining additional information on the customer and beneficial owner, sources of funds and wealth, reasons for the transaction, as well as obtaining senior management approval to establish or continue the relationship. Additionally, the Directive allows Member States to impose further restrictions on conducting business relationships.

Last update: 13 March 2024