AML/CFT Policy

The Anti-Money Laundering, Countering Financing of Terrorism and Know Your Customer Policy (hereinafter - the "AML/CFT Policy") of XRP Arbitage is designated to prevent and mitigate possible risks of XRP Arbitage being involved in any kind of illegal activity.

Money laundering is defined as

• The conversion or transfer of property derived from criminal activity...
• The acquisition, possession or use of property derived from criminal activity...
• The concealment or disguise of the true nature, source, location, disposition, movement...

Money laundering also means participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the activities referred to above.

Terrorist financing is defined as the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism.

Both international and local laws and regulations require XRP Arbitage to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery, and to take action in case of any form of suspicious activity from its Users.

AML/CFT Policy covers the following matters

• Internal controls
• Compliance officer
• Training of personnel
• Verification procedures
• Monitoring, risk assessment, and risk-based approach
• AML/CFT program audit

Internal Controls

We have designed a structured system of internal controls in order to comply with applicable Anti-Money Laundering, Countering Financing of Terrorism (AML/CFT) laws and regulations, including, but not limited to:

• Establishing customer's identity and verifying the information provided
• Special regime for dealing with politically exposed persons (PEP)
• Identifying unusual activity and reporting suspicious transactions
• Keeping records of customer documentation and transaction history

Compliance Officer

The Compliance Officer is the person, duly authorized by XRP Arbitage, whose duty is to develop and enforce the effective implementation of AML/CFT. The Compliance Officer is required to report any violations of the AML/CFT procedures and is responsible for collecting and filing Suspicious Activity Reports (SARs).

• Developing and updating internal policies for compliance
• Collecting and verifying user identification data
• Analyzing suspicious transactions and investigating unusual activities
• Reporting suspicious activity to appropriate authorities

Training

All employees receive a full AML/CFT training, along with job-specific guidance. Training is conducted at least once every twelve (12) months to ensure compliance with all applicable laws and regulations.

Verification Procedures

XRP Arbitage establishes its own customer verification procedures within the standards of AML/CFT frameworks. We conduct due diligence and KYC checks before entering business relations with a customer, client, or contractor.

Monitoring, risk assessment, and risk-based approach

The Compliance Officer conducts investigations for incoming and outgoing transactions based on various factors. Transactions are monitored, and suspicious activity is detected using specialized tools and a high-performance system.

AML Audit

The Compliance Officer is responsible for conducting AML/CFT audits at least annually. Other audit demands are set in internal policies and procedures.

We apply due diligence measures, in particular

• Upon establishment of a business relationship
• Upon verification of gathered information or doubts about existing data
• Upon suspicion of money laundering or terrorist financing
• Identifying 'red flags' in accordance with internal procedures

Preservation of data

We retain the originals or copies of documents that serve as the basis for identification and verification of persons for no less than five years after termination of the business relationship.

Our monitoring of a business relationship includes, in particular

• Checking transactions to ensure they align with the customer's known activities
• Regularly updating customer documents and verification data
• Identifying the source and origin of funds
• Detecting complex, high-value, and unusual transactions