AML/KYC | FOXCHANGE

Introduction

Money laundering and the financing of terrorism are financial crimes with economic effects. To qualify as an illegal activity, it requires an underlying, primary, profit-making crime (such as corruption, drug trafficking, market manipulation, fraud, tax evasion), along with the intent to conceal the proceeds of the crime or to further the criminal enterprise. This is a process in which the identity of the proceeds of crime is so disguised, that it gives an impression of legitimate income.

The purpose of AML/KYC policy is, by increasing the trustworthiness and transparency of the business environment, to prevent the use of the financial system for money laundering and terrorist financing. We adhere to strict laws rendering it illegal for our company to knowingly engage in or attempt to engage in any activities remotely related to money laundering. Our anti-money laundering policy is designed to increase protection and enhance client security services, as well as to offer safe payment processes.

AML/CFT controls, when effectively implemented, mitigate the adverse effects of criminal economic activity, including adequate systems and controls in place to alleviate the risk of committing financial crime. The policy establishes requirements aimed at the identification and analysis of the customers’ activities in order to prevent the company's interaction with persons engaged in activities related to the legalization of proceeds from crime and the financing of terrorism.

1. The customers’ verification and identification

The first safeguard against money laundering is KYC verification. To ensure compliance with standard AML regulations, we require you (the customers) to fill and submit the following information:

Personal information, such as name, date of birth, address, contacts;
The identity documents, such as passport or ID card;
In some cases (for risk mitigation) proof of residence, such as utility bill, bank account statement and others official documents issued within the last 3 months clearly stating your name and address as registered with FOXCHANGE;
Identification of legal entities involves the following information: name, legal form, registration address, registration number, name of the person acting on behalf of the person, contacts, business activity. Document confirming the authority of the person who performs actions on behalf of the legal entity. Such as an extract from the register, which contains the names of Directors, the Charter of the company, from which the powers of Directors are evident, and the power of attorney. The document should contain data on the powers and terms of authority.
Please note that, we may need to request further documentation from our customers (such as card verification, and bank information).

FOXCHANGE will take steps to confirm the authenticity of the documents and information provided by the customer.

Please note: All required documents should be provided in good quality, all texts should be readable, and there should not be any modifications or edits of the document photos, as otherwise we would have to reject them and request new copies without modification or in better quality.
We shall send a notice of decision to accept or to refuse the customer as our client. The customers receive acceptance only after all requested documents are provided. This means that the company must gather information of the customers’ identity and verify their documents before applicants to our services will be accept as the users. Documenting and maintaining these identification procedures enhances company’s ability to prevent money laundering activities.
FOXCHANGE sets different levels of regulatory protection to each customer within each risk profile.
We have the right to impose additional due diligence requirements to accept the customer residing in certain countries, for politically exposed persons or for effective risks mitigation relating to money laundering and terrorist financing.
FOXCHANGE reserves the right to verify customers’ identity on an on-going basis, especially, when their identification information was changed or activity seemed to be suspicious (unusual for the particular user). In addition, we reserve the right to request up-to-date documents from the customers, even though they have passed identity verification in the past.
Please note, if you (the customer) want (s) to deposit amounts of over EUR 15,000.00 (fifteen thousand) per month, we will request from them to fill a questionnaire asking for information on “Source of Funds” and to attach of all relevant supporting documents to justify your statements. If this information is not satisfactory, the company reserves the rights to request additional information and documentation.
If a customer was identified as:

a politically exposed person (“PEP”), or
a PEP’s family member (* the spouse or a person considered to be equivalent to a spouse, * a child and their spouse or a person considered to be equivalent to a spouse, * a parent), or
a person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations

We apply enhanced due diligence measures and request all necessary information for risk mitigation and prevention of money laundering.
We don’t allow for the customer to have more than one account on our platform. If it is detected that a customer has more than one account, all of the accounts will be temporarily disabled and the customer will have to provide an explanation of this situation.
Customer’s identification information will be collected, stored, shared and protected strictly in accordance with our Privacy Policy and related regulations.

2. Monitoring

The customers are known not only by verifying their identity, but, more importantly, by analyzing their transaction activities. Therefore, FOXCHANGE relies on the data analysis as a risk-assessment and suspicion detection tool.
Our company tracks all suspicious operations of users. If we suspect illegal activities or money laundering, we have the right to delay, terminate or cancel such transaction at any stage In addition, we reserve the right to suspend or terminate any account or freeze funds in the account, if there is any reason to believe that the account was used for activities that was deemed illegal or fraudulent.

The customers activities that the company considers to be the possible indicators for money laundering:
The customer is interested in financial transactions that are not of sufficient transparency or which contravene the AML policy;
The customer can’t provide information about the legality of sources of funds; or provide false or misleading information about the source of funds;
The customer appears in the news in cases of civil or criminal offenses;
The customer can’t easily describe the nature of his activity;
The customer wants multiple accounts and large number of transactions between them;
There is a surge in activity on the previously inactive account.

This list is not exhaustive. The company thoroughly monitors and analyzes the activities of our customers and their accounts, and, in cases of suspicious transactions, requests to provide any additional information and documents.
Please note, that transactions of suspicious nature are reported to the proper law enforcement.
According to the law, FOXCHANGE is not obligated to give any notifications to the customer about their suspicions of customer’s criminal actions.

3. Payments by third party

We do not accept third-party payments. All deposits must be made in the customer’s own name and match the KYC documents submitted. For the funds to be withdrawn, we accept only wire transfer to your bank account. Additional, we don’t accept cash deposits or disburse cash for withdrawal.

4. Restrictions

The company doesn’t open accounts for anonymous owners (i.e. without providing primary information before establishing business relationship). Each customer undertakes to carry out operations individually and independently. If the company has suspicions of passing control over the account management to the third party by the customer, we request full information about the third party and explanation from the customer about the reasons and causes for of this situation. In addition, the company reserves the right:

To terminate account activities;
To block access to your personal account;
To cancel transactions.

5. Sanctions Policy

FOXCHANGE doesn’t establish business relationships with individuals, companies and countries that are included in the sanctions lists by United Nations (UN), European Union (EU), UK Treasury and US Office of Foreign Assets Control (OFAC), Financial Action Task Force (FATF).

6. Anti-Fraud

FOXCHANGE is committed to conducting business in accordance with the highest ethical, professional and legal standards. We will comply with applicable legislation. In line with applicable legislation, our company has a ‘zero tolerance’ policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct. Our policies are compliant with the current applicable local and international legislation.
We perform KYC due diligence on all new customers and a due diligence on all transactions in order to detect possible compliance or integrity concern. Such due diligence is executed in accordance with the requirements of the money laundering and terrorist financing activities regulations, pursuant to the terms of KYC (see previous clauses). Such instruments as KYC, transactions monitoring and account activities analysis help us prevent or fast detect and investigate fraud and anti-money laundering by customers.

7. Miscellaneous

The obligated entity arranges adherence to and implementation of the rules, procedures and internal control mechanisms by the employees of the obligated entity. The company provides training and raises awareness among all the relevant employees. The training includes, but is not limited the following topics:

Understanding and detecting money laundering and fraud;
Verifying customer identification;
Identifying suspicious activity and structured transactions;
Reporting requirements related to all transactions.

Pursuant to the EU legislation, we store all information about customers for 5 years following termination of business relationships..

If you have any inquiries, please contact us via email: support@foxchange.ch

Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) Policy