Anti-Money Laundering Program

1. INTRODUCTION

EXMO recognises the significant risks posed by financial crimes such as money laundering, terrorist financing, sanctions evasion, fraud, corruption, and other forms of financial crime. EXMO is committed to conducting its business with integrity and in a manner that reflects its regulatory, ethical and social responsibilities.

In particular, EXMO is committed to:

• Protecting its users, employees (including permanent staff and contractors), and business partners;
• Safeguarding the integrity of its platform; and
• Support governments, regulators, and law enforcement authorities in the prevention, detection, and investigation of financial crime.

EXMO maintains a zero-tolerance approach to deliberate or wilful breaches of applicable financial crime laws and regulations, including but not limited toe.g. bribery and corruption, money laundering, terrorist financing, sanctions violation, tax evasion, fraud, and market abuse.

This Anti-Money Laundering Program (“AML Program”) provides a high-level overview of EXMO’s AML and financial crime compliance framework. It does not disclose confidential or sensitive operational procedures.

2. AML PROGRAM OVERVIEW

EXMO maintains a comprehensive AML Program designed in accordance with the Financial Action Task Force (FATF) Recommendations and applicable national AML and counter-terrorist financing regulations relevant to virtual asset service providers.

The AML Program is designed to prevent, detect, and mitigate the misuse of EXMO’s services for unlawful or prohibited activities and includes, at minimum, the following core components:

• Development, implementation, and enforcement of internal AML and financial crime policies, procedures, and controls proportionate to identified risks;
• Compliance with all applicable AML, CFT, sanctions, and financial crime rules, regulations, and guidance issued by the relevant authorities;
• Implementation of Know Your Customer (KYC), Customer Due Diligence  (CDD), and, where applicable, Enhanced Due Diligence (EDD) measures;
• Timely identification, escalation and reporting of suspicious activity in accordance with applicable reporting obligations;
• Ongoing monitoring of user activity, transactions, and relationships to identify unusual or suspicious behaviour;
• Maintenance of accurate, complete and up-to-date records relating to customers, accounts, transactions, and investigations;
• Appointment of an independent Compliance Officer, responsible for oversight, administration, and effectiveness of the AML Program, with direct access to senior management and, where applicable, the Board of Directors;
• Periodic independent testing and audits of the AML Program to assess effectiveness and regulatory compliance;
• Compliance with the applicable recordkeeping and record retention obligations; and
• Delivery of ongoing AML and financial crime  training to all relevant employees.

3. POLICIES AND PROCEDURES

EXMO has developed and implemented AML policies and procedures that align with recognised industry standards and regulatory expectations for virtual asset service providers. These policies are risk-based and designed to:

• Identify and assess money laundering and terrorist financing risks associated with customers, products, services, delivery channels, and geographic exposure;
• Apply controls and mitigation measures proportionate to the level of identified risk; and
• Ensure timely detection, investigation, and escalation of potentially suspicious activity.

AML policies and procedures are reviewed and updated regularly to reflect changes in applicable laws and regulations, evolving industry standards and guidance, and emerging financial crime risks and typologies.

All AML policies and procedures:

• Are approved by the Board of Directors;
• Are accessible to all relevant employees at all times;
• Are subject to at least an annual review cycle, providing senior management with assurance regarding the effectiveness of EXMO’s financial crime control framework.

4. TRAINING 

EXMO maintains a comprehensive AML and financial crime training program applicable to all employees, with enhanced training for individuals involved in onboarding, transaction monitoring,investigations, and compliance functions.

Training is tailored to EXMO’s business model and risk profile, is delivered on a regular basis and upon onboarding of new employees, and is designed to ensure staff understand their legal, regulatory, and internal obligations.

Training content includes, among other topics, AML and CFT obligations, sanctions compliance, customer due diligence requirements, identification of suspicious activity  and financial crime typologies, escalation and reporting procedures, and individual accountability and consequences of non-compliance.

5. SANCTIONS COMPLIANCE

EXMO is committed to complying with applicable economic and trade sanctions, including those imposed by the United States Office of Foreign Assets Control (OFAC), the European Union (EU), the United Nations (UN), the United Kingdom (UK), and any other applicable sanctions authorities.

Sanctions screening and controls are applied, on a risk-based basis, to new and existing customers, counterparties and third party service providers, employees, where relevant, and cryptocurrency wallets and incoming and outgoing virtual asset transactions.

6. ANTI-BRIBERY, ANTI-CORRUPTION, AND ANTI-FRAUD

EXMO maintains a zero-tolerance approach to bribery, corruption, and fraud. All employees and third parties acting on behalf of EXMO are prohibited from engaging in any form of bribery or corrupt conduct.

Anti-Bribery and Corruption (“ABC”) requirements are integrated into EXMO’s broader financial crime compliance framework. ABC training forms part of EXMO’s financial crime training programme, and covers, among other areas, dealings with Politically Exposed Persons (PEPs), gifts, hospitality and entertainment, donations and business courtesies, and conflict of interest.

Anti-fraud measures include employee training focused on external and internal fraud risks, segregation of duties and internal controls, and mandatory consecutive periods  of leave to mitigate the risk of internal fraud.

7. RESTRICTED COUNTRIES AND TERRITORIES

EXMO restricts or prohibits access to its services from certain jurisdictions based on applicable sanctions regimes, regulatory requirements, and internal risk assessments. The list of restricted jurisdictions may change from time to time in response to regulatory developments or risk considerations.

EXMO also does not accept users from disputed or unrecognized territories.

8. GOVERNANCE AND OVERSIGHT

Senior management and, where applicable, the Board of Directors maintain oversight of the AML Program and are responsible for ensuring that EXMO maintains an effective and proportionate financial crime compliance framework.