AML Policy

Introduction
xGroup Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of xGroup being involved in any kind of illegal activity. International and local regulations necessitate that xGroup implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users. xGroup takes this business very seriously and has a zero tolerance policy for abusers.
AML/KYC Policy covers the following:
•Verification procedures.
•Compliance Officer.
•Monitoring Transactions.
•Risk Assessment.
1. Verification procedures One of the international standards for preventing illegal activity is customer due diligence (“CDD”). Specific to these principles, xGroup has established its own verification procedure within the standards of anti-money laundering and “ Know Your Customer”frameworks.
1a. Identity verification xGroup’s identity verification procedure requires the User to provide xGroup with reliable, independent original color copy source documents, data or information (examples include: national ID, international passport, bank statement, utility bill). xGroup will take steps to confirm the authenticity of documents and information provided. All legal methods for confirming identification information will be used and xGroup reserves the right to investigate certain Users who have been determined to be of a higher risk. xGroup reserves the right to verify and update User’s identity on an on-going basis, especially when their identification information has been changed or their activities change and become unusual for a particular user. In addition, xGroup reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past. User’s identification information will be collected, stored, shared and protected strictly in accordance with the xGroup’s Privacy Policy and related regulations. Once the User’s identity has been verified, xGroup is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1b. Card verification
The Users who are intending to make a payment to xGroup must pass our payment verification
process in accordance with instructions available on xGroup Site.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by xGroup, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of xGroup’s anti-money laundering and counter-terrorist financing, including but not limited to:
2a. Collecting Users’ identification information.
b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
c. Monitoring transactions and investigating any significant deviations from normal activity.
d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
e. Updating risk assessment regularly.
f. Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
System Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, in certain cases, xGroup will rely on data analysis as a risk-assessment and suspicion detection tool. xGroup will perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

System functionalities include:

3a.Where new customers are concerned, Check of Users against recognized “black lists” (e.g. OFAC), place Users on watch and service denial lists, opening “tickets” for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
3b. Case and document management. With regard to the AML/KYC Policy, xGroup reserves the right to monitor all transactions; ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; request system User provide any additional information and documents in case of suspicious transactions; suspend or terminate User’s Account when xGroup has reasonable suspicion that such User engaged in suspicious activity.
The above list is not exhaustive and the Compliance Officer reserves the right to monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Risk Assessment
xGroup, in line with the international requirements, has adopted a risk-based approach to combating money laundering and potential terrorist financing. By adopting a risk-based approach, xGroup is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient way. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

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