AML Statement

Updated: October 18, 2024

Purpose of the Policy

The purpose of this AML Policy is to prevent the use of our services for any form of financial crime, as defined under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, and other relevant UK legislation governing anti-money laundering (AML) practices. Namely, we adhere to the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering Regulations 2017 as well as general Financial Action Task Force (FATF) recommendations. Our procedures and practices are aligned with our Terms and Conditions and Privacy Policy, ensuring the lawful and secure use of our platform.

Data Collection and Usage

BoxExchanger’s AML/CTF/CPF program reflects our strong commitment to applying Client Due Diligence (CDD) measures in line with global Anti-Money Laundering (AML) standards. These CDD practices are core to our overall risk management strategy, designed to safeguard the integrity of our operations and the security of financial transactions. We meticulously collect and verify essential client documentation to ensure transparency and reliability in our dealings as a trusted counterparty.

As part of this process, we may gather and process the following types of information:

Personal Identification: This includes the client's full name, email address, phone number, home address, date of birth, nationality, and, if applicable, their tax identification number. This data is vital for establishing the client’s identity.

Technical Data: We collect technical data related to platform usage, such as IP addresses and activity history, to ensure the security of our platform.

Photo Identification: Clients must provide a valid passport or other government-issued photo ID (excluding driver’s licenses). Additionally, we require a real-time selfie along with a photo of the provided ID to confirm identity authenticity.

Additional Personal and Corporate Information: Documentation such as proof of address, details about the source of funds, and evidence of the source of wealth are collected to assess the client's financial profile and mitigate risks. All collected data is used solely for compliance with our internal AML policy and requirements to maintain the security of our platform and users. We may retain this data for a period of up to five years following the conclusion of the business relationship.

Sharing relevant Client data with third parties: As part of our commitment to compliance with applicable anti-money laundering (AML) regulations and other legal requirements,BoxExchanger Limited reserves the right to share relevant Client data with third parties,including but not limited to our service providers, banking partners, and regulatory authorities.This may occur in order to meet our AML obligations under the relevant financial institutions' laws of our partners. All data sharing will be conducted in accordance with applicable data protection regulations.

Client Due Diligence

For the purposes of Client Due Diligence (CDD), BoxExchanger could identify its Client unless the identity of that Client is already known to, and has been verified by the service provider. The amount of information to be received from a Client depends on whether the Client is a legal entity or an individual (natural person), namely:

If a client is a legal entity, the following information may be requested to fulfill CDD requirements: a company name; registration number; address of the registered office (and, if different, its principal place of business); the law to which the legal person is subject; its constitution (whether set out in its articles of association or other governing documents); full names of the board of directors (or if there is no board, the members of the equivalent management body) and the senior persons responsible for the operations of the legal entity.

If a client is an individual (natural person), then the following information may be requested for identification purposes: a name and surname; personal identity number (if such exists); date of birth; photograph on an official document which confirms a Client’s identity; residential address; number and date of issue of the personal identification document, state and authority which has issued the document; period of validity of the identification document.

Clients Who Refuse to Provide Information

BoxExchanger reserves the right to terminate any business relationship if a client fails to submit the required documentation or provides false or misleading information during the AML verification process. This measure ensures compliance with regulatory obligations and maintains the integrity and security of our operations.

List of Acceptable Identification:

Current passport.
Current National Identity Card.
Travel Documents (issued in the UK by the Home Office).
Current EU Residence Permit (issued by the Home Office).
Current full UK photocard driving license (provisional licenses are acceptable for U18s only).
Current full UK driving license (old-style paper version).
HM Revenue & Customs tax notification.
Recent Benefits Agency letter (Department for Work & Pensions, Jobcentre Plus, Benefits Agency, Veterans Agency) confirming the client’s right to benefits.

List of Acceptable Address Verification:

Council tax bill (valid for the current year);
Utility bill (dated within the last 6 months);
Telephone bill (dated within the last 6 months) – mobile phone bills are not acceptable;
Sky or Cable TV bills (dated within the last 6 months);
Credit card bill (dated within the last 6 months). Certain conditions may apply for overseas financial providers;
Bank, Building Society, Credit Union statement – showing current activity (dated within the last 6 months). Certain conditions may apply for overseas financial providers;
Mortgage statement from a recognised lender (dated within the last 12 months);
Home Office letter confirming the right to work in the UK (dated within the last 6 months);
Disabled parking document (blue or orange);
HM Revenue & Customs tax notification;
Current motor insurance certificate/schedule (a cover note is not acceptable).

Prohibited Jurisdictions

The use of the website BoxExchanger is prohibited for citizens and/or residents of the following countries/territories:

Afghanistan, American Samoa, Chad, Cuba, Democratic People's Republic of Korea (North Korea), Democratic Republic of the Congo, Federal Republic of Ambazonia, Guam, Haiti, Iran, Iraq, Jamaica, Kosovo, Lebanon, Libya, Myanmar (Burma), Nicaragua, Northern Mariana Islands, Palestine, Republic of Belarus, Republic of Sudan, Russian Federation, Somalia, South Sudan, State of Palestine, Syria, Transnistria, Trinidad and Tobago, Turkish Republic of Northern Cyprus, U.S. Virgin Islands, Venezuela, Western Sahara, Yemen, the temporarily occupied territories of Georgia, and the temporarily occupied territories of Ukraine.

Service Restriction Jurisdictions

BoxExchanger reserves the right to refuse services to the following jurisdictions:

Albania, Bahamas, Barbados, Burkina Faso, Cambodia, Cameroon, Central African Republic, China, Côte d'Ivoire, Liberia, Mali, Mozambique, Nicaragua, Pakistan, Philippines, Puerto Rico, Senegal, South Africa, Tanzania , Trinidad and Tobago, Turkmenistan, Uganda, Vanuatu, Viet Nam, Western Sahara, and Zimbabwe.

Transaction Monitoring

BoxExchanger operates within a dynamic financial ecosystem, supporting a broad range of fiat currencies (GBP, EUR, USD) and a diverse selection of cryptocurrencies or virtual assets, including Bitcoin, Ethereum, and USDT on Ethereum and Tron blockchains, together with Litecoin (LTC), among other virtual assets. BoxExchanger utilizes its own back-office infrastructure, which integrates advanced blockchain analytics to monitor transactions within the blockchain ecosystem and identify wallets linked to illicit activities. As part of its ongoing transaction monitoring efforts, BoxExchanger utilizes blockchain analytics systems as part of its trusted relationships with our processing partners. This enables the company to proactively track and address suspicious transactions, ensuring compliance with regulatory standards and maintaining the integrity of its operations.

Training and Awareness

BoxExchanger is dedicated to maintaining an effective training program for all employees involved in due diligence and monitoring activities on a regular basis. This ensures that team members are fully equipped to handle their responsibilities related to Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing (CPF).

The training aims to provide employees with the practical skills needed to identify and address activities associated with financial crime. It goes beyond theoretical knowledge, offering hands-on guidance based on the operational procedures and regulatory frameworks. Employees are also informed about the mechanisms available for reporting violations.

Appropriate and regular training will be provided to all staff members in line with their roles and required knowledge levels. This will cover, at a minimum:

Legal and regulatory obligations
Roles in handling criminal property and terrorist financing
Management of money laundering and terrorism financing risks
Identifying money laundering or terrorism financing transactions
Internal processes for reporting suspicious transactions or activities

Policy Review and Updates

This Policy will be reviewed annually to ensure its compliance with legislative changes and best practices. We are committed to notifying users of any significant changes that affect their rights or obligations.

AML Disclaimer

At BoxExchanger, we adopt and follow best practices aligned with industry standards to enhance our compliance with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Counter-Proliferation Financing (CPF) regulations. BoxExchanger Limited is not classified as a regulated financial institution under UK law. While our services do not impose a legal obligation to enforce AML requirements, we maintain these safeguards to promote transparency and integrity.

This commitment is driven by our dedication to safeguarding both our business and the broader industry as a responsible service provider. This policy details the measures we have implemented to ensure compliance with applicable legal obligations, while also clarifying how these practices are integrated with our Terms and Conditions and Privacy Policy.

Conclusion

BoxExchanger recognizes the serious implications of money laundering and is committed to maintaining effective controls within its policies and practices to deter such activities, even in the unique context of operating without personal data collection. It is the responsibility of all employees to adhere to the principles set out in this policy statement to safeguard the integrity and reputation of BoxExchanger.