Money laundering is a method of covering up illegal resources by converting them into cash or other seemingly legitimate investments. XchangeOn is extremely serious about offering our customers the best customer service possible by focussing on account security. In order to prevent money laundering in any shape or form, we are implementing the KYC (Know Your Customer) policy. In this respect, the Anti-Money Laundering Policy (hereinafter referred to as the "AML Policy") summarized the procedures and mechanisms set by XchangeOn to prevent money laundering.
The main objective of the Anti-Money Laundering Policy is to minimize the risk by evaluating customers, transactions and services of XchangeOn . With a risk-focused approach, to inform employees about laundering of crime revenues and funding of terrorism and provide information in this regard, and to inform customers that the Company abides by the applicable regulations, mainly, the Law on the Prevention of Laundering Crime Revenues no. 5549 and the Law on Prevention of Financing Terrorism.
Within the scope of this AML Policy, to avoid any damage to the activities of the Company, customers to which the AML policy shall apply are real persons and/or legal entities who are members of the Platform accessed on https://xchangeon.io/, who benefit from the services offered by the Platform, and who accept the conditions of the AML Policy.
XchangeOn has issued its AML Policy in accordance with international law norms and standards, and applicable legislation. The Company has taken many measures such as adequate verification of the identities of all customers, risk-based approach for monitoring customer transactions, notifying any suspicious transactions by customers to related institutions and authorities in line with the legislation and registering such transactions, and coordinating the implementation and feasibility of the AML Policy at the Company.
XchangeOn adopts a risk-based approach towards money laundering and the financing of terrorism in accordance with national and international requirements. Thus, the measures for preventing money laundering and financing of terrorism are proportionate to the identified risks, and allows effective allocation of resources. Resources are used on a priority basis and the greater risks receive more priority.
Since XchangeOn adopts a risk-based approach in monitoring the financial activities of its customers, it carries out risk analysis through the following methods in order to prevent money laundering and financing of terrorism, and it may monitor customers according to the information obtained as a result of risk analysis.
Customers and transactions in the high-risk group are as follows:
The monitoring of customer transactions and analysis of acquired data is also an important means of risk assessment and detection of suspicious transactions. If there is any suspicion of money laundering, XchangeOn has the right to monitor all transactions (customers and transactions in the high risk group, complex and unusual transactions, transactions with high-risk countries, documents and information belonging to customers, written and obligatory information to be maintained regarding sale and purchase of cryptocurrencies, transactions carried out by customers- whether such transactions are in line with applicable information, etc.) and take the following actions:
Above is not an exhaustive list, the AML Policy Compliance Officer monitors customers’ transactions on a daily basis, and determines whether to report the customers and deem them as suspicious.
XchangeOn will establish its own standards to combat money laundering and to determine compliance with the Know Your Customer (KYC) policy.
XchangeOn customers must complete a verification procedure (they are obliged to present identity documents approved by official authorities: passport or identity card). XchangeOn reserves the right to collect customer information for AML purposes. Such information is processed and safely maintained according to the XchangeOn Confidentiality Policy.
XchangeOn may request a second Customer ID: (Bank receipt or electricity/water bill not older than 3 months, including the full name and actual address of the customer).
XchangeOn reserves the right to request more information from Customers deemed as risky or suspicious after verifying the accuracy of the documents and information submitted by customers.
If the Customer’s identity information has been altered, or their actions are deemed suspicious, XchangeOn retains the right to request updated documents even if the previous identity has been verified in the past.
In cases of suspected money laundering and financing of terrorism related to the services provided by XchangeOn, transactions deemed as suspicious after the necessary inspections are reported to the Financial Crimes Investigation Board, regardless of the amount of the transactions. The real persons performing the suspicious transaction, and their representatives, executives and employees who do not comply with the obligation to report suspicious transactions, will be liable for all kinds of legal, administrative and penal sanctions.
The Anti-Money Laundering Officer is a XchangeOn employee who is responsible for ensuring compliance with the AML Policy: The Anti-Money Laundering Officer is charged with.
XchangeOn fulfils all of its obligations concerning training on staff policy and procedures, issued in line with the applicable legislation. In this respect, the Company provides trainings, mainly on the Procedure for Preventing Money Laundering, and ensures that this information is kept up to date.
XchangeOn conducts periodical audits to check whether the Company policies and procedures regarding directives and notifications on the “Law Against Money Laundering and Financing of Terrorism” are in line with the applicable legislation.
