ANTI MONEY LAUNDERING & KNOW YOUR CUSTOMER POLICY

1. POLICY STATEMENT 

PEXOOM (Pexoom LLC with its registered office at Suite 305, Griffith Corporate Centre, Beachmont Kingstown, St. Vincent and the Grenadines, with limited liability company number 3055, e-mail: info@pexoom.com and support@pexoom.com) and its employees, third parties, its customers, and clients are at all times committed to the highest standards of anti-money laundering (AML) and counter-terror financing (CTF), including anti-fraud, anti-corruption, and taking measures to mitigate against financial crime. 

The terms "We", "Our", "Company", PEXOOM and "Us" refer to PEXOOM Exchange and the terms "User", "You" and "Your" refer to a User of our Online Platforms (Website and/or Mobile Application). 

2. BACKGROUND 

PEXOOM is a Company registered as per the Laws of St. Vincent and the Grenadines. This Policy describes the Company's procedures instituted to ensure that the services offered by the Company are not being used by the users to facilitate the commission of any criminal offences, including but not limited to those under the Corruption, Drug Trafficking and Other Serious Crimes and relevant applicable laws. The Company has prepared this AML Policy to ensure the transparency of trading and to ensure the prevention of money laundering and other illegal activities. 

3. PURPOSE & STATEMENT OF OBJECT 

In order to mitigate its risks relating to money laundering and other illegal activities, PEXOOM intends to put in place this policy the KYC and Due Diligence Procedure including Risk Management Procedure; Customer Verification Procedure; Transaction Monitoring Terms and other relevant processes as defined below. 

4. KEY TERMS 

4.1.What is Money Laundering and Terrorist Financing? 

• Money laundering is the illegal process of making large amounts of money generated by criminal activity, such as drug trafficking or terrorist funding, appear to have come from a legitimate source. 
• Terrorism financing is the provision of funds or providing financial support to individual terrorists or non-state actors. The objective of such financing is to support terrorist acts or support terrorist organizations that commit terrorist acts.

4.2.Data Protections 

In designing procedures and measures to mitigate AML/CTF risk, regard will be given to the rights and freedoms of citizens as regard to the protection of personal data. The measures designed will be proportionate and in compliance with the regulations of the geographies where PEXOOM operates. 

5. KYC & DUE DILIGENCE PROCEDURES 

PEXOOM adheres to and complies with the principles of the Know Your Customer (KYC) policy which aims to prevent financial crime and money laundering through client identification and due diligence. 

If the Company finds any user information obtained in accordance with the procedure described under this clause to be inadequate, insufficient, or sanction screened, the Company may in its discretion either refuse or terminate (as the case may be) the registration of such user account or require verification of such users identification documents again. 

All customers/clients, who are new to the organization will undergo procedural due diligence checks prior to opening an account, as laid out below: 

5.1.Primary Verification Identification 

Proof of who every new individual or business is will be gained and recorded on a New Customer Application. 

The very first step when transacting on the Platform would be to produce documentation that would verify Identification, Address, and Selfie/ Liveness checks. 

Identification & Address Proof: Documents for Identification and home/office address are required with the person/business name on. Acceptable forms of ID can include: 

• Individual: Drivers License, Passport, Bank Statement, Utility Bill (in all markets except India). For India, PAN Card and/or AADHAAR Card details are required for KYC. The Company reserves all the rights to get the verification of your PAN and/or Aadhaar done from the government authorities. 
• Business: Details of any beneficial owners / controlling directors, 

Director/Proprietor ID (as per requirements for individuals), Certificate of Incorporation, Company Registration Number & Registered Office, Utility Bill, Bank Statement. 

Selfie-check/ Liveness Check: As part of the selfie-taking/ liveness check process the user is asked to position their face within an oval on the screen, about 12 inches away, and

then move a bit closer. The company takes its KYC procedures seriously however, the process of selfie/ liveness check is subject to the technical issues faced by the company. 

5.2.Secondary Verification 

The company conducts a secondary verification in the following scenarios: 

• For transactions over 10 million USD either by the Individual or the Business, ● For users having a large number of outward transactions on our website, as the company deems alarming, 
• For any suspicious activity as per the company’s policies, rules and regulations, and laws of the land, 
• For any User or transaction of the user having a high negative score from any of our third-party compliance tools, etc. 
• In the above-mentioned scenarios, the Users would require a subsequent step after those mentioned under Clause 5.1. In such a case a User will be asked to undergo a Video KYC and provide additional proofs as required by the company. 

Herein, a Source of the Funds and verification of the above point, KYC ought to be mentioned and only upon the verification of the same will the Platform allow for further transactions to take place. 

5.3.Due Diligence Checks 

As we understand the importance of due diligence checks and ongoing due monitoring; we will conduct background checks prior to account acceptance, details of which will be kept on file as evidence of due diligence and anti-money laundering checks. 

Due diligence checks will be conducted as per the regulations and requirements. All documents, accounts, and transactions associated with clients/customers will be retained based on the laws and regulations of the country that the user signs up. 

5.4.Monitoring & Auditing Due Diligence 

The Company has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for ensuring that due diligence checks and anti-money laundering measures are being completed and are fit for purpose. Regular audits are completed on due diligence forms, company checks, and ongoing monitoring. 

Team will conduct ongoing due diligence checks for client/customer accounts. This will ensure we keep up-to-date information and data and will also keep a check that no adverse information has arisen since the last due diligence was performed.

A risk-based approach will be followed while conducting due diligence and no transactions will be conducted with sanctioned or banned individuals/ entities. 

5.5.Sanction Screening 

As part of our on-boarding process as well as ongoing due diligence process; all the individual and corporate customers, connected parties of the customer, ultimate beneficial owners of the customer will undergo the screening process. No business or transactions will be conducted with the sanctioned individuals or entities. 

5.6.Enhanced Due Diligence (EDD) 

Where a customer is assessed as higher risk either internally by the Company, then Enhanced Customer Due Diligence (EDD) measures are applied by the company. That includes senior management review and sign-off of new business relationships. The Company follows a process that allows for the identification of potential red flags as well as checks on behaviour, pattern, and volume of the transactions. 

Enhanced monitoring to be conducted on a risk-based approach of any business relationship or transactions involving a high-risk third country or where any potential concerns are identified during standard due diligence. 

5.7.Record Keeping 

PEXOOM will ensure that records of all Customer Due Diligence (CDD) documentation and customer transactions are held for a term as mandated by the laws and regulations of the country that the user signs up from. 

These records include but are not limited to CDD documentation, Business wide risk assessments, customer risk assessments.) 

6. RISK MANAGEMENT PROCEDURE 

• The Company may categorize its Users including you into low, medium, or high-risk categories, after undertaking an appropriate risk assessment of each User based on the following factors (including without limitation) 
• Sufficiency and adequacy of identification information submitted as mentioned under this policy. 
• Its social and/or financial status; or 
• Nature of Users business/vocational activities; or
• Guidance notes circulated by various governmental and intergovernmental organizations. You acknowledge that in order to maintain the integrity of the Risk Management Procedure, the Company will keep your risk categorization and any data related thereto confidential. 

You will not be entitled to seek disclosure of your risk categorization. However, the Company may disclose the Users risk categorization data to the competent enforcement authority if it finds that a particular User has executed or is likely to execute any Suspicious Transaction. 

7. OUTSOURCING 

For the purposes of verification of any users identity and monitoring of transactions, the Company relies on appropriate and licensed third-party service providers to authenticate the identification and other incidental details provided by you. 

As part of the on-boarding process; due diligence will be conducted for such service providers. 

8. CONTACT US 

You may report your concerns directly to us, at any point, whether or not you have used our internal procedures and whether or not an internal investigation is in fact ongoing at support@pexoom.com.

9. REVIEW OF THE POLICY 

This policy will be subject to periodic review in the light of various factors including regulatory changes, changes in business, market intelligence, and industry standard.