Anti-Money Laundering Policy
DigiCounted LTD (collectively “Company” or "digicounted") are incorporated under English law and offers services through an internet marketplace for the purchase and sale of digital products.
The Company is not registered as a Money Services Business with the Financial Conduct Authority (FCA), however, Digicounted Anti-Money Laundering (“AML”) policies and procedures are designed to deter illicit activities on the platform, protect the users, the business and financial services communities from exploitation by criminals. The Company is compliant with the Money Laundering Regulations and guidance.
As part of Digicounted Compliance policies, Know Your Customer (“KYC”) policies and procedures for individual and institutional customers have been designed to enable the Company to form a reasonable belief that it knows the true identity of those of its customers for which such review has been performed. The policy applies to all users on the platform and is followed by all of the Company’s employees, consultants, officers, owners and directors.
Using a risk-based approach as part of KYC & AML Compliance, DigiCounted has taken the following measures:
>> Appointment of a Chief Compliance Officer who has a sufficient level of expertise and independence and has responsibility for the oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
>> Establishing and maintaining risk-based KYC, Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) Policy;
>> Establishing risk-based tiers for verification of the Company's users;
>> Cooperation with law enforcement requests and local regulatory requirements;
>> Decentralized Autonomous Organizations ("DAO");
>> Filing of Suspicious Activity Reports (“SARs”);
>> Company-wide BSA/AML/CTF training;
>> Ongoing rule-based transaction monitoring;
>> Use of various anti-fraud systems;
We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on our platform. A suspicious transaction is often one that is inconsistent with a user’s known and legitimate business, personal activities or personal means. Our Chief Compliance Officer reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR. Our Chief Compliance Officer maintains records and supporting documentation of all SARs that have been filed.
The Company has also adopted the use of the UK Sanctions List
designed to protect the platform from being used for prohibited transactions, by sanctioned individuals or for the purposes of evading, avoiding or otherwise circumventing global sanctions.
DigiCounted fully cooperates with the Financial sanctions targets by regime lists. Please refer to the Financial sanctions targets by regime list
of the banned individuals that are prevented from using the DigiCounted platform.
DigiCounted has taken the measures to ensure developed written procedures and supporting processes to prevent, detect, and report suspicious customer/merchant activity;
DigiCounted has an internal audit function or other independent third parties that assesses AML policies and practices on a regular basis;
DigiCounted is prohibited from doing business with shell banks.
DigiCounted AML policies and procedures applied to all of its branches and subsidiaries regardless of the country in which they operate;
DigiCounted conduct an enterprise AML risk assessment to identify risks associated with our customers, products, services, and geographic locations;
DigiCounted has implemented customer identification policies and procedures that are in line with local laws/regulations;
If required by local laws/regulations, DigiCounted will obtain and verify the customer's ultimate beneficial ownership (UBO) information;
DigiCounted has a process to review, and where appropriate, update, the KYC policies and information for high-risk clients;
DigiCounted assesses its customers' AML policies and practices, when applicable;
DigiCounted screens customers against global and domestic sanctions lists and works with third-party vendors Civic Technologies and Persona Identities Inc for identity verification.
DigiCounted has a transaction monitoring program designed to identify and freeze unusual or suspicious transaction activity;
DigiCounted communicates new AML-related laws or changes to existing AML-related policies or practices to relevant employees;
This document was drafted and certified collectively by the Chief Compliance Officer of DigiCounted