XEXON AML Policy

1. Purpose and Scope

This policy outlines XEXON’s commitment to preventing money laundering and terrorist financing across all services offered. It ensures compliance with both international and domestic regulations.

2. Appointment of Compliance Officer

XEXON will appoint a dedicated Anti-Money Laundering Compliance Officer (AMLCO) responsible for overseeing compliance activities, including transaction monitoring, reporting, internal audits, and staff training.

3. Customer Due Diligence (CDD) and Risk Assessment

  • KYC Procedures: Verification of identity using government-issued ID and proof of address at account registration.

  • Risk-Based Approach: Customers are assessed based on transaction behavior, geographic risk, profession, and other factors.

  • Ongoing Monitoring: Customer profiles and transaction patterns are regularly reviewed and updated.

4. Transaction Monitoring and Reporting

  • Real-Time Monitoring: Transactions are continuously screened using automated systems to detect suspicious behavior.

  • Suspicious Activity Reporting (SAR): Any detected suspicious activity is reported to the relevant authority in accordance with applicable laws.

  • Currency Transaction Reporting (CTR): Large transactions that exceed defined thresholds are logged and reported as required.

5. Compliance with the Travel Rule

In accordance with FATF’s Travel Rule, XEXON collects and shares originator and beneficiary information for cryptocurrency transfers above the applicable threshold.

6. Sanctions and PEP Screening

  • Sanctions Lists: Customers are screened against international sanctions lists (e.g., OFAC, EU) to prevent prohibited transactions.

  • Politically Exposed Persons (PEPs): PEPs and their associates are subject to enhanced due diligence procedures.

7. Employee Training and Internal Audit

  • Regular Training: All staff receive ongoing AML training to remain informed of procedures and emerging risks.

  • Internal Audit: Periodic audits are conducted to assess the effectiveness of the AML program and identify areas for improvement.

8. Record Keeping

All customer identification data, transaction records, and compliance reports are securely maintained for a minimum of 5–7 years, in accordance with applicable regulations.

9. Policy Review and Updates

This AML Policy will be reviewed and updated regularly to reflect legal changes, regulatory updates, and industry best practices.