test

Anti Money Laundering Policy

Excelon Exchange is subject to regulation designed to combat Money Laundering and Terrorist Financing as set out in the laws of Estonia, European Union directives and Financial Action Task Force (“FATF”) guidelines.

We are committed to maintaining the highest feasible standards of compliance with these requirements in order to prevent our Services being used for facilitation or benefit of criminal activity.

The defined terms used in this document are the same as those set out in the [Service Terms of Use].

Chief Anti-Money Laundering Officer

Excelon Exchange has appointed a Chief Anti-Money Laundering Officer (the “CAMLO”) who reports to senior management and the board of directors. The CAMLO has the responsibility, authority and resources to ensure the effective implementation and enforcement of the AML Policy.

Client identification and verification

We may, on registration of your Account with us and at any time thereafter, request that you provide us with your Personal Information, including, but not limited to, your name, address, telephone number, electronic mail address and date of birth, as well as your source of funds, financial standing and occupation. We may also verify your details, at any time, by requesting certain documents from you. These documents may typically include a government issued identity card, proof of address such as a utility bill, and proof of your payment method. In addition, we may request further information with respect to our Anti-Money Laundering and Know Your Customer obligations. In addition, we may request that copies of such documents be notarised and apostilled at your own expense. We shall be under no obligation to accept any documents as valid if such documents fail our internal security checks – for example, if we suspect that they have been tampered with, or are in any way proven to be misleading or misrepresenting –, and under no obligation to provide feedback on the exact nature of our findings with regards to these documents. In addition, we may request that you attend a video call to verify your identity.

We may also perform further background and verification checks on you and request any relevant documentation from you or from any third party for any reason, and for that purpose you hereby authorise us to, directly or indirectly (through third parties), make any inquiries we consider necessary to check the relevance and accuracy of the documents and information provided for verification purposes.

User’s Personal Informationwill be collected, stored, shared and protected strictly in accordance with the Excelon Exchange Privacy Policy, which can be found [here]. We will, at a minimum, update client Personal Informationat least every two years.

Risk assessment

In accordance to regulatory and legal requirements in force, Excelon Exchange has adopted a risk-based approach to combating money laundering and terrorist financing. As such we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. Clients are individually risk-assessed based on the collected Personal Information and their resulting risk profile determines our business relationship.

Limits

We apply limits to the amount of Virtual Assets that you will be able to gain exposure to per transaction and to the amount of Virtual Assets or Fiat funds you can transfer in to, or out from, your Account with Excelon Exchange. These limits will be determined at Excelon Exchange’s sole discretion and may be amended and adjusted from time to time. Any limits as described above will be outlined whilst using the Services.

The use of all Excelon Services is subject to a limit on the amount of volume you may transact or transfer in a given period (e.g., daily). Your limits may vary depending on your payment method, verification steps you have completed, and other factors.

You can find the full list of limits regarding all functions of Excelon Exchangewhen you log into your Account. We reserve the right to change applicable limits as we deem necessary. You can submit a request any time via emailin order to alter your limits.

Enhanced Due Diligence

We may require you to submit additional information about yourself or your business, provide records, and arrange for meetings with Excelon Exchange’s staff (such process, “Enhanced Due Diligence”). We reserve the right to charge you costs and fees associated with such Enhanced Due Diligence although if we intend to do so, we will notify you in advance. In our discretion, we may refuse to raise your limits or we may lower your limits at a subsequent time even if you have completed Enhanced Due Diligence.

Transaction monitoring

We will, as part of our AML-CTF obligations, monitor your transactions for suspicious activity. If we detect suspicious activity in your Account we may, to our complete discretion, block any transaction, ask you for details regarding past transactions, or report to the relevant authorities.

Information on Transfers

Virtual Asset and Fiat Transfers in, and out of, Excelon Exchange, must be accompanied by certain mandatory information about originator and beneficiary, which in some cases, according to regulations in force, must be accurate and verified. You understand and agree that we reserve the right to ask you this information and that, if such information is not satisfactory to our standards, we may: ask you for additional information and supportive documentation, block the transfer, return the Virtual Assets or Fiat funds to their origin or report the transfer to the relevant authority.