Anti-Money Laundering Policy

CoinOrder is committed to reducing the risk that its services may be used for money laundering, terrorist financing, fraud or other unlawful financial activity.

CoinOrder may apply risk-based compliance measures appropriate to the nature of a user, transaction or activity.

These measures may include:

• identity verification
• transaction monitoring
• suspicious activity review
• sanctions and restricted-party screening
• source-of-funds review
• enhanced review of higher-risk activity
• appropriate record keeping

CoinOrder may request information including:

• full name
• date of birth
• nationality
• government-issued identification
• passport information
• photographs or selfie verification
• contact information
• other information reasonably required for verification

Transaction activity may be reviewed for risk indicators such as:

• unusual transaction values
• unusual transaction frequency
• activity inconsistent with expected account behaviour
• indicators associated with fraud
• transactions requiring additional verification

Where appropriate, CoinOrder may request information or documentation concerning source of funds or transaction purpose.

This may include:

• bank records
• income evidence
• transaction history
• business information
• other documentation reasonably supporting the source of funds

Users and transactions may be screened against applicable sanctions, restricted-party or other relevant risk information.

Higher-risk activity may be subject to enhanced verification or review.

Where unusual or suspicious activity is identified, CoinOrder may take measures including:

• requesting additional information
• delaying transactions
• restricting certain functionality
• declining transactions
• suspending access to relevant services
• taking other steps reasonably required by applicable obligations

Users must not:

• use another person's identity
• provide false or misleading information
• conceal the true source of funds
• transact on behalf of unauthorised third parties
• use CoinOrder for unlawful financial activity

CoinOrder may maintain verification, transaction and compliance-related records for periods reasonably necessary to satisfy security, operational and applicable compliance requirements.

This policy may be updated to reflect changes in risk, services, operational practices or applicable requirements.