KYC / AML policy

1. Introduction

Know Your Customer (KYC) and Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) procedures exist to make sure financial services are not used for crime. They protect you, other users and the wider financial system.

This policy describes what we ask for, why we ask for it and what happens next. It should be read together with our Privacy Policy.

These rules apply to every user whatever the size of the deposit. A small starting amount does not mean lighter checks, because criminals often test systems with small sums first.

2. What is KYC

KYC is the process of identifying a customer and checking that the information they provide is true. In practice it means we match your name, date of birth and address against an official document and, where required, against your face.

KYC is carried out when you open an account, again before large or unusual transactions and from time to time to keep information current.

KYC is not a one-off exercise. If your circumstances change, for example you move house or renew a passport, please update us so our records stay accurate and your account stays in good standing.

3. What is AML / CTF

AML/CTF covers the measures a business takes to prevent the proceeds of crime from being disguised as legitimate money, and to stop funds reaching terrorist activity. It includes assessing the risk each customer presents, monitoring activity for suspicious patterns and reporting concerns to the regulator.

In Australia the regulator is AUSTRAC. We design our program around its guidance for providers of services involving virtual assets.

Money laundering usually has three stages: placing dirty money into the system, layering it through many transactions to hide its origin and integrating it as apparently clean funds. Our controls are designed to interrupt each stage.

4. Why identity verification is required

Verification stops fraudsters from opening accounts in someone else’s name, protects your account from takeover and helps us meet our legal obligations. It also lowers the financial risk to you, because withdrawals go only to accounts that belong to you.

We cannot offer a full service to a user we have not identified. This is a legal requirement, not a preference.

Honest users benefit directly. Because identities are checked, the risk that a withdrawal request is made by someone impersonating you falls sharply, and the platform is far less attractive to organised fraud.

5. Documents we may request

For identity we accept a current Australian driver licence, passport or photo card. For proof of address we accept a recent bank statement, utility bill or government letter dated within the last three months, showing your name and residential address.

We may also ask for a selfie or a short liveness check to confirm that the person in the document is the person using the account. We ask only for documents we actually use.

We do not accept photocopies of photocopies, edited screenshots or documents with covered-up details. Names on your documents must match the name on your account and on the payment method you use.

6. The verification process

• Register and give your name, date of birth, address and contact details.
• Upload your documents through the secure form in your account.
• Automated checks compare the data, test the document and match the selfie.
• A compliance officer reviews anything the automated step cannot settle.
• You are notified of the result by email, and by your account manager if more is needed.

Most users complete the steps in under ten minutes. Your account manager can walk you through the upload on the phone if you prefer, although they will never ask you to send documents by email or chat.

7. Enhanced due diligence

Higher-risk situations call for a closer look. Examples are large deposits, unusual patterns, links to higher-risk countries or a customer who holds a prominent public position. In those cases we may ask about your source of funds or source of wealth.

Typical supporting documents are payslips, tax returns, sale contracts or statements showing where the money came from. Being asked does not mean you have done anything wrong.

Enhanced due diligence is proportionate. We ask for what we need to understand the risk and no more, and we explain why we are asking so that you can decide how to respond.

8. How long verification takes

Many checks finish within one business day. Time depends on how clear your documents are, whether the automated checks pass first time and how busy the compliance team is.

Incomplete or blurry uploads cause most delays. Photograph documents flat, in good light, with all four corners visible.

If a review is likely to take longer than expected we will tell you so, and your account manager will give you a realistic date. You may use the simulator while you wait.

9. Reasons for rejection or suspension

We may reject or pause verification if a document is expired, unreadable or appears altered, if the details do not match, if the account holder cannot be confirmed or if information requested is not provided.

We may also suspend an account where we reasonably suspect fraud or other unlawful activity. Where we can, we tell you the reason and how to fix it.

If we reject a verification you can usually try again with better documents. If we cannot proceed at all, we will explain what happens to any funds already in your account and how to withdraw them.

10. Transaction monitoring

We monitor deposits, withdrawals and account activity for unusual patterns, such as rapid movement of funds with no apparent purpose. Monitoring combines automated rules with human review.

If something looks suspicious we may limit certain features while we look into it. The law may prevent us from telling you that a report has been made.

Where we are required by law to report a suspicion we must do so without notifying you. This is a legal duty on us, and not a sign that we have judged you.

11. Your responsibilities

You must provide accurate, current and genuine information and documents, and tell us promptly if your details change. You must not use the platform for unlawful purposes or let anyone else use your account.

Giving false information can lead to closure of the account, withholding of funds as the law allows and referral to the authorities.

Do not allow another person to use your account, even a relative. Doing so breaks our terms and can create legal problems for both of you.

12. Data retention and protection

We keep KYC and AML records securely and for the minimum period Australian law requires, normally seven years after the relationship ends. Access is limited to staff who need it for compliance work.

How we handle this data is explained further in the Privacy Policy.

Verification files are held apart from marketing data. Our staff are trained on handling identity documents, and access is logged so that any unusual access can be investigated.

13. Sharing information

We may share KYC information with identity verification providers, IT suppliers who host our systems, group companies and, when required by law, regulators and government agencies such as AUSTRAC.

Every provider we use is bound by contract to protect your data and use it only for the purpose we give it.

We never sell identity data. Sharing is limited to what is necessary for verification, hosting or a legal duty, and a recipient may not reuse the information for another purpose.

14. Compliance with requirements

Our program is designed around the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the rules and guidance that AUSTRAC issues under it, together with the privacy rules that apply to the information we collect.

We review the program regularly and update it when the rules change. See Licensing and regulation for the regulators involved.

Compliance is overseen by a named officer with responsibility for the AML/CTF program, who reports to senior management on a regular basis and arranges independent reviews of the program.

15. Contact and support

For questions about verification, AML or this policy, write to [email protected]. Include your account email, but do not attach identity documents to an ordinary email. Use the secure upload in your account instead.

We aim to reply to compliance questions within two business days. For urgent security matters, call your account manager instead.