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Anti-Money Laundering (AML) Policy

1. Scope

This Anti-Money Laundering (AML) Policy applies to all operations of Onyx Trade Ltd. ("the Company") and outlines the procedures and responsibilities to prevent money laundering (ML) and terrorist financing (TF).

This policy is designed to comply with the relevant legal and regulatory requirements and to ensure that our operations are conducted with the highest standards of integrity.

2. Terms

ML (Money Laundering): The process of concealing the origins of money obtained through illegal activities, typically by means of transfers involving foreign banks or legitimate businesses.

TF (Terrorist Financing): The process of providing financial support to terrorist organizations to carry out terrorist activities.

KYC (Know Your Customer): The process of verifying the identity of our clients to ensure they are who they claim to be.

CDD (Customer Due Diligence): The measures taken to identify and verify customers, including ongoing monitoring of their transactions and activities.

3. Grounds

This policy is based on the following frameworks and regulations:

FATF Recommendations (R.40): International standards set by the Financial Action Task Force to combat money laundering and terrorist financing.

AIFC Anti-Money Laundering, Terrorist Financing, and Sanctions Rules: Local regulations applicable within the Astana International Financial Centre.

The Company must also adhere to sanctions imposed by the following authorities:

  • Kazakhstan state authorities and agencies

  • National Bank of Kazakhstan

  • Astana Financial Services Authority (AFSA)

  • United Nations Security Council (UN SC)

  • Office of Foreign Assets Control (OFAC) of the United States

  • United Kingdom (UK)

  • European Union (EU)

4. KYC Measures

Given that the Company will onboard clients on a non-face-to-face basis, the following measures must be implemented:

  1. Identification: Clients must provide a valid ID or passport.

  2. Address Proof: Clients must provide proof of address, such as a bank statement, utility bill, or other document issued by an independent party within the last three months.

  3. Face Recognition: Each customer must pass through a face recognition process using the SUMSUB solution.

5. KYT (Know Your Transaction) Transactions Monitoring

The Company will monitor transactions to detect suspicious activities and ensure compliance with sanctions. The following measures will be enforced:

  • Transactions involving digital assets under sanctions by OFAC, UK, EU, and Kazakhstan are strictly prohibited.

  • Continuous monitoring and analysis of transaction patterns to identify and report suspicious activities.

6. Risk-Based Approach

The Company employs a risk-based approach to AML compliance.

This means:

  • Assessing the risk levels associated with customers, transactions, and jurisdictions.

  • Implementing enhanced due diligence measures for high-risk customers and transactions.

  • Making decisions to limit or terminate services in specific jurisdictions or to specific nationals based on risk assessments.

7. Freezing Accounts and Source of Funds Verification

The Company reserves the right to:

  • Freeze a customer's wallet if suspicious activities are detected.

  • Require customers to provide explanations and proof documents regarding the source of funds and source of wealth.

8. Customer Responsibilities

Customers must understand and acknowledge that:

  • The Company has the authority to freeze their wallets and request additional information if needed.

  • Compliance with AML regulations is mandatory and any non-compliance may result in account restrictions or termination.

This policy might be amended on a time to time basis.

If you have any questions related to this topic, please feel free to contact us at aml@onyxtd.kz