1. Introduction
AXK Omni ("we," "us," or "our") is committed to preventing money laundering and any activity that facilitates money laundering, terrorist financing, or other financial crimes. This Anti-Money Laundering (AML) Policy establishes our principles and procedures for complying with applicable AML laws and regulations.
We operate in a highly regulated industry and take our legal and regulatory responsibilities seriously. This policy applies to all employees, officers, directors, and contractors of AXK Omni, as well as to our users and customers.
2. Purpose and Scope
The purpose of this AML Policy is to:
- Establish a framework for preventing money laundering and terrorist financing
- Ensure compliance with applicable AML laws and regulations
- Protect our reputation and integrity
- Mitigate the risk of our platform being used for illicit purposes
- Establish clear procedures for customer verification and transaction monitoring
- Define roles and responsibilities for AML compliance
This policy applies to all of our operations globally, including all digital wallet services, payment processing activities, currency exchange services, and other financial services we provide.
3. Definitions
For the purposes of this policy, the following definitions apply:
- Money Laundering: The process of converting illegally obtained funds to make them appear legal. It typically involves three stages: placement (introducing illegal funds into the financial system), layering (concealing the source of the funds through complex transactions), and integration (returning the funds to the launderer in a seemingly legitimate form).
- Terrorist Financing: The solicitation, collection, or provision of funds with the intention that they be used to support terrorist acts or organizations.
- Know Your Customer (KYC): A process of identifying and verifying the identity of clients and assessing potential risks associated with their activities.
- Customer Due Diligence (CDD): Measures taken to identify customers and verify their identities, understand the nature of their activities, and assess money laundering risks.
- Enhanced Due Diligence (EDD): Additional due diligence measures applied to customers presenting higher risk.
- Politically Exposed Person (PEP): An individual who is or has been entrusted with a prominent public function, such as a head of state or government, senior politician, senior government official, judicial or military official, senior executive of a state-owned corporation, or an important political party official.
- Suspicious Activity Report (SAR): A report made to the relevant financial intelligence unit about suspicious or potentially suspicious activity.
4. Know Your Customer (KYC)
AXK Omni implements a robust KYC program to ensure we know the true identity of our customers and the nature of their activities. Our KYC procedures include:
4.1 Customer Identification
Before establishing a business relationship or conducting transactions, we collect and verify the following information from all customers:
- Full name and date of birth
- Permanent residential address
- Valid government-issued identification (passport, national ID card, driver's license)
- Contact information (email address and phone number)
- Additional information as required based on risk profile and jurisdiction
4.2 Customer Due Diligence (CDD)
We conduct appropriate CDD measures for all customers, including:
- Identity verification using reliable, independent sources
- Assessment of the nature and purpose of the business relationship
- Understanding the anticipated pattern of transactions
- Ongoing monitoring of the business relationship and transactions
4.3 Enhanced Due Diligence (EDD)
We apply EDD measures for higher-risk customers, including:
- Politically Exposed Persons (PEPs)
- Customers from high-risk countries identified by FATF or other relevant authorities
- Customers engaged in high-risk activities
- Customers with complex ownership structures
- Customers flagged during monitoring for unusual transaction patterns
EDD measures may include obtaining additional identification information, verifying sources of funds or wealth, obtaining senior management approval, and conducting enhanced ongoing monitoring.
5. Risk Assessment
We employ a risk-based approach to AML compliance, which involves:
5.1 Customer Risk Assessment
Customers are categorized based on risk factors including:
- Geography (country of residence, citizenship, and operation)
- Customer type (individual, business, non-profit)
- Business or occupation
- Types of products and services used
- Transaction patterns and volumes
- Delivery channels used
5.2 Business-Wide Risk Assessment
We regularly conduct and document a comprehensive risk assessment of our business, considering:
- Products and services offered
- Customer base
- Geographic areas of operation
- Technology used for service delivery
- Regulatory environment
5.3 Risk Mitigation
Based on identified risks, we implement appropriate controls to mitigate money laundering and terrorist financing risks. Risk assessments are reviewed and updated regularly to ensure our AML controls remain effective and relevant.
6. Transaction Monitoring
We maintain systems and procedures to monitor customer transactions for suspicious activities. Our transaction monitoring includes:
6.1 Automated Monitoring
We employ automated systems that:
- Screen transactions against risk rules and scenarios
- Flag unusual patterns, frequencies, or amounts
- Detect structured transactions designed to evade reporting thresholds
- Identify transactions with high-risk jurisdictions
- Monitor sudden changes in transaction patterns
6.2 Transaction Thresholds
We apply transaction limits and enhanced verification requirements based on user risk profiles and transaction volumes. Transactions exceeding certain thresholds trigger additional verification steps.
6.3 Ongoing Monitoring
We conduct ongoing monitoring throughout the business relationship to:
- Ensure transactions are consistent with our knowledge of the customer
- Maintain current customer information and risk profiles
- Reassess risk levels based on changes in transaction patterns or customer behavior
7. Suspicious Activity Reporting
AXK Omni has established procedures for identifying, investigating, and reporting suspicious activities:
7.1 Identification of Suspicious Activity
Potential indicators of suspicious activity include:
- Transactions that appear to have no legitimate business purpose
- Unusual patterns of transactions inconsistent with the customer's profile
- Multiple transactions just below reporting thresholds
- Transactions involving high-risk jurisdictions
- Reluctance to provide identification or information
- Unusual sources of funds
- Transaction activity inconsistent with stated purpose of account
7.2 Internal Reporting
All employees must promptly report suspicious activities to the AML Compliance Officer. Employees are prohibited from disclosing the fact that a SAR has been filed or is being considered ("tipping off").
7.3 External Reporting
The AML Compliance Officer will review reported suspicious activities and determine whether a Suspicious Activity Report (SAR) or other notification should be filed with the appropriate regulatory authorities in accordance with applicable laws and regulations.
8. AML Compliance Officer
AXK Omni has designated an AML Compliance Officer who is responsible for:
- Developing, implementing, and maintaining our AML program
- Ensuring compliance with applicable AML laws and regulations
- Reviewing and investigating suspicious activity reports
- Filing regulatory reports as required
- Conducting regular risk assessments
- Developing and delivering AML training
- Serving as the primary point of contact for regulatory authorities
- Providing periodic reports to senior management and the Board of Directors
The AML Compliance Officer has sufficient authority, resources, and access to senior management to carry out these responsibilities effectively.
9. Training Program
We provide comprehensive AML training to ensure all employees understand their responsibilities:
9.1 New Employee Training
All new employees receive AML training as part of their onboarding process, covering:
- Overview of AML laws and regulations
- Our AML policies and procedures
- Red flags for suspicious activity
- Reporting requirements and procedures
- Consequences of non-compliance
9.2 Ongoing Training
All employees receive regular refresher training at least annually or when significant changes occur in AML requirements or our procedures.
9.3 Specialized Training
Employees in higher-risk roles or with specific AML responsibilities receive additional specialized training relevant to their functions.
9.4 Training Records
We maintain records of all AML training, including materials, attendance, dates, and test results if applicable.
10. Recordkeeping
We maintain comprehensive records of our AML compliance program, including:
- Customer identification and verification documents
- Transaction records
- Investigation files and documentation of decisions
- Suspicious activity reports and supporting documentation
- Risk assessments
- AML training materials and attendance records
- Compliance reviews and audit reports
All records are retained for a minimum of five years, or longer if required by applicable laws or regulations, and are maintained in a form that is readily retrievable upon request from authorized regulatory authorities.
11. Sanctions Compliance
AXK Omni is committed to complying with economic and trade sanctions administered by various national and international authorities, including:
- United Nations Security Council (UNSC)
- Office of Foreign Assets Control (OFAC)
- European Union (EU)
- UK Office of Financial Sanctions Implementation (OFSI)
- Other applicable sanctions authorities
11.1 Screening Procedures
We screen customers and transactions against applicable sanctions lists. Screening is conducted:
- During customer onboarding
- When sanctions lists are updated
- Prior to processing transactions
- Periodically throughout the business relationship
11.2 Prohibited Relationships
We do not establish or maintain relationships with individuals or entities on applicable sanctions lists, or those located in comprehensively sanctioned countries or regions.
12. Policy Review
This AML Policy is reviewed at least annually to ensure it remains current, comprehensive, and effective. Reviews consider:
- Changes in applicable laws and regulations
- Changes in our business activities or geographic reach
- Results of internal and external compliance assessments
- Industry developments and best practices
- Feedback from regulatory examinations
Any changes to this policy are approved by senior management and communicated to all employees.
13. Consequences of Non-Compliance
Non-compliance with this AML Policy may result in:
- For employees: Disciplinary action up to and including termination of employment
- For AXK Omni: Significant regulatory fines, civil or criminal penalties, reputational damage, and potentially the loss of licenses or business authorizations
- For customers: Account restrictions, suspension, or termination, and potential reporting to regulatory authorities
We maintain a zero-tolerance approach to willful or repeated violations of our AML policies and procedures.
