AML & CTF Policy.
Purpose
First Xchange maintains a robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework designed to comply with the laws and regulations of the jurisdictions in which it operates. Our policy prevents the use of First Xchange services for money laundering, terrorist financing or any other unlawful activity.
1. Programme overview
- Customer identification (KYC) and risk profiling
- Ongoing transaction monitoring
- Record-keeping and reporting
- Staff training and independent audits
- Appointment of a dedicated Chief Compliance Officer (CCO)
2. Customer due diligence
- Full legal name, date of birth, address and nationality
- Government-issued photo identification
- Proof of residence (bank statement or utility bill)
- For corporate clients: registration documents, ownership structure and authorised signatories
Enhanced Due Diligence (EDD) applies to high-risk individuals, politically exposed persons (PEPs) and jurisdictions with weak AML standards.
3. Ongoing monitoring
- Rapid deposits or withdrawals inconsistent with a customer’s profile
- Layering of transactions across multiple wallets or accounts
- Transactions involving sanctioned or high-risk countries
- Use of mixing services or privacy coins
Suspicious activity is flagged for internal review and, where warranted, reported to the competent authority.
4. Record keeping
Identification and transaction records are retained for at least five (5) years after account closure, stored securely and accessible only to authorised personnel.
5. Reporting obligations
First Xchange files suspicious transaction reports, large virtual-currency transaction reports and other reports required by the regulators to which it is subject.
6. Sanctions and screening
- United Nations sanctions lists
- National and regional sanctions lists in our operating jurisdictions
- International watchlists and PEP databases
7. Staff training
All employees and contractors receive mandatory AML/CTF training at onboarding and annually thereafter, covering suspicious-behaviour identification, due-diligence handling, escalation procedures and confidentiality.
8. Independent review
The AML/CTF programme undergoes annual independent audits by external compliance professionals.
9. Non-compliance consequences
- Account suspension or termination
- Regulatory reporting to the relevant authority or law enforcement
- Legal proceedings where applicable
10. Compliance enquiries
Chief Compliance Officer
First Xchange
support@firstxchange.com