SpinCoin Anti-Money Laundering (AML) Policy

Last Updated: 13/05/2021

1. Introduction

SpinCoin is committed to preventing money laundering and terrorist financing through the implementation of robust policies and procedures. This Anti-Money Laundering (AML) Policy outlines our approach to detecting and preventing illicit activities in compliance with applicable laws and regulations.

2. Purpose

The purpose of this policy is to:

• Ensure compliance with relevant AML laws and regulations.
• Establish a framework for detecting and reporting suspicious activities.
• Protect SpinCoin from being used as a conduit for illegal activities.
• Promote a culture of compliance and ethical behavior within the organization.

3. Scope

This policy applies to all SpinCoin employees, officers, directors, and agents, as well as any third parties acting on behalf of SpinCoin.

4. Responsibilities

4.1 Board of Directors

The Board of Directors is responsible for overseeing SpinCoin’s AML program and ensuring that adequate resources are allocated for its implementation.

4.2 Compliance Officer

A designated Compliance Officer will manage and supervise the AML program. The Compliance Officer's duties include:

• Developing and updating AML policies and procedures.
• Ensuring that all employees are trained on AML requirements.
• Monitoring and reporting suspicious activities.
• Maintaining records of AML compliance activities.

4.3 Employees

All employees must adhere to this AML Policy and report any suspicious activities to the Compliance Officer.

5. Customer Due Diligence (CDD)

5.1 Identification

Before establishing a business relationship, SpinCoin will verify the identity of all customers through reliable and independent sources. Required information may include:

• Full name
• Date of birth
• Address
• Identification number (e.g., passport, driver's license)

5.2 Risk Assessment

Customers will be classified based on their risk profiles (low, medium, high). Enhanced due diligence measures will be applied to high-risk customers, including:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Transactions involving large sums of money

6. Monitoring and Reporting

6.1 Transaction Monitoring

SpinCoin will monitor customer transactions to detect patterns that may indicate money laundering or other illicit activities. Automated systems and manual reviews will be used to analyze transactions for unusual or suspicious behavior.

6.2 Reporting Suspicious Activities

If suspicious activities are detected, they will be reported to the appropriate authorities in accordance with applicable laws. Reports may include:

• Large or unusual transactions
• Transactions that appear to have no legitimate purpose
• Transactions involving high-risk customers

7. Record Keeping

SpinCoin will maintain comprehensive records of customer identification, transaction details, and reports of suspicious activities for a minimum of five years. These records will be stored securely and made available to regulatory authorities upon request.

8. Training and Awareness

All employees will receive regular training on AML laws, regulations, and internal policies. Training will cover:

• The importance of AML compliance
• How to identify and report suspicious activities
• Updates on new regulations and industry practices

9. Internal Controls and Audit

9.1 Internal Controls

SpinCoin will implement internal controls to ensure the effectiveness of its AML program. These controls will include regular reviews of policies, procedures, and systems.

9.2 Independent Audit

The AML program will be subject to periodic independent audits to assess its effectiveness and compliance with relevant laws and regulations. Audit findings will be reported to senior management and the Board of Directors.

10. Sanctions Compliance

SpinCoin will comply with all applicable sanctions regimes. Customers and transactions will be screened against relevant sanctions lists, and any matches will be reported to the appropriate authorities.

11. Reporting and Escalation

Any employee who becomes aware of a potential violation of this policy must report it immediately to the Compliance Officer. Failure to comply with this policy may result in disciplinary action, including termination of employment.

12. Review and Updates

This AML Policy will be reviewed and updated annually, or as required by changes in laws and regulations. Any updates will be communicated to all employees and relevant stakeholders.