Group AML Policy

 

Anti-Money Laundering Compliance Program

Thanks for visiting Transak; we are on a mission to make Web3 applications accessible!

We have developed Anti-Money Laundering Compliance Program (”AML Program”) in an effort to maintain the highest possible compliance standard in accordance with applicable laws and regulations relating to anti-money laundering in the United States, United Kingdom and other countries where Transak conducts business.

In an effort to mitigate any risk associated with money laundering, the financing of terrorism and any other illicit activity, we have implemented procedures and internal controls applicable to the services provided by Transak. This includes, but is not limited to:

  • Establishing robust internal policies, procedures and controls that identify and prevent any attempted use of Transak for illegal or illicit purposes and that are designed to ensure our customers are protected;
  • Complying with the applicable regulations and guidance put in place by the Financial Crimes Enforcement Network (“FinCEN”), Financial Conduct Authority (”FCA”) and other regulatory authorities in the jurisdictions in which we operates;
  • Filing the necessary reports required by law for any suspected suspicious activity.
  • Maintaining comprehensive records of orders and other transfers;
  • Employing a Compliance Officer/Money Laundering Reporting Officer responsible for the implementation and oversight of our AML Program and day to day operations;
  • Executing Know Your Customer (“KYC”) procedures on all customers;
  • Performing checks and balances on our AML programs through independent audits
  • Following record retention requirements; and
  • Implementing a risk-based approach for the mitigation of any risks.

Policy Statement

Transak’s management and board will ensure that the firm adheres to its regulatory requirements at all times. The firm has an unequivocal zero-tolerance approach to money laundering, terrorist financing, sanctions evasion and other financial crime, and takes the risks seriously.

Scope

This Policy applies to all Transak Group entities and affiliates.

Risk Assessment

In compliance with regulatory requirements, Transak has adopted a risk based approach to identify any risks associated with money laundering and terrorist financing through the use of our services. We have a dedicated team that ensures all risks are assessed, mitigated and monitored with the intention to safeguarding our customers and our platform.

For any questions, please contact our support team at [email protected]

Policies and Procedures

Our BSA/AML Program has been reviewed and approved by our Board of Directors (the “Board”). Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies.

Internal Controls

We have developed robust internal policies, procedures, and controls designed to comply with applicable regulations including our Customer Identification Program. In addition to the verification of a customer’s identity and in order to identify and mitigate risks, Transak employs a risk based approach by conducting transaction monitoring. This process requires the analysis of data, transactional activity, behaviors and other data points that together attribute to a client risk rating and decision making.

Our internal controls are designated to meet statutory and regulatory standards. As part of our internal controls, Transak may request additional information to verify your identity, source of funds, source of wealth, address, among other requests with the only purpose of validating the activity on your account.

Compliance Officer

The development and implementation of policies and procedures for our AML Program fall under the responsibility of our Group Head of Compliance. Transak has designated a responsible individual to support and enforce compliance across our products and services. This includes overseeing the day-to day operations. Transak’s Group Head of Compliance through the Compliance Department will be responsible for creating policies and procedures designed to verify our customers’ identity, source of funds as well as other information permitted under the applicable laws.

Customer Identification Program

Transak complies with a Customer Identification Program (CIP), which relies in the use of multi-level systems and procedures to collect and verify information about our customers and partners. This allow us to comply with record-keeping requirements and to minimize the risk of the platform being used for illicit or fraudulent activities.

Prior to opening an account for an individual customer, we will collect, verify, and authenticate the following information:

  • Full name
  • Email address;
  • Mobile phone number;
  • Social Security Number (“SSN”) or any comparable identification number issued by government;
  • Date of birth (“DOB”);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID);
  • Residential/ home address (not a mailing address or P.O. Box); and
  • Selfie
  • Other personal identifiable information may be requested in order to verify our customers’ identity, purpose of account and transactional activity.

We conduct checks against international government watchlists, including the Office of Foreign Assets Control (“OFAC”), Office of Financial Sanctions Implementation and others. Failure to complete any of these steps will result not being able to use Transak.

Once the above steps are successfully completed, you will be asked to accept our standard Terms & Conditions and Privacy Policy. Failure to do so will result in an account not being opened.

Law Enforcement Requests

Law Enforcement Agencies should first contact our support team at [email protected] in connection with any requests for information or subpoenas. Our team will review the inquiry and assign it to the responsible department or individual.

Transak will only disclose user data in response to valid legal processes, therefore, any requests from non-law enforcement officials will not be addressed.

Overly broad or vague requests for information cannot be processed by Transak. Any legal request must properly and specifically identify the requested records and include information that allow us to identify the customer account(s) at issue by providing the customer’s name and or email addresses.

We do not provide expert testimony support. And, our records are self-authenticating pursuant to United States law and should not require testimony of a records custodian for admission. If a special form of certification is required, please include it with your process.

Responses can take from 30 days to 45 days from receipt to complete, depending on the complexity of the request.