TOP EXCHANGERS ‘S Anti-Money Laundering Policy
TopExchangers.com as a currency exchange provider has a responsibility and a commitment to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorism or any other criminal activities. To fulfill this goal, we have implemented a specific and comprehensive internal Anti-Money Laundering Policy.
What is Money Laundering?
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages:
- Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s cheques, or deposited into accounts at financial institutions;
- at the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin; and
- at the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
AML Compliance Officer Designation and Duties
TopExchangers.com designates its CEO as its Anti-Money Laundering Program Compliance Officer (“AML CO”), to supervise TopExchangers.com’s AML Program. The AML CO is qualified by experience, knowledge and training, including subscriptions to monthly newsletters, which identifies new industry issues. He receives an electronic subscription to the Compliance Reporter, which compiles regulatory news stories segregated by category and date. To supplement these sources, the AML CO attends regulatory conferences. TopExchangers.com has also designated a backup AML CO.
The supervisory duties of the AML CO include: monitoring the Company’s AML compliance, overseeing communication, as well as coordinating and conducting training for employees. The AML CO will also ensure that proper AML records are kept.
Customer Identification and Verification.
We collect certain customer identification information from each customer who opens or maintains an account. We record customer identification information, verification methods, and the results; documents are requested of all existing clients and prospective clients are notified that certain documents are required in order to open an account. We verify customer identity through documentary evidence, non-documentary evidence, or both. We use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever possible. We may also use such non-documentary means, after using documentary evidence, if we are still uncertain about whether we know the true identity of the customer. In analyzing the verification information, we will consider whether there is a logical consistency among the identifying information provided, such as the customer’s name, street address, zip code and telephone number.
We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government- issued identification as verification of a customer’s identity. If, however, we note that any document shows some obvious form of fraud, we consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity.
Additional Areas of Risk TopExchangers.com has reviewed all areas of its business to verify that all potential money laundering risks are covered in the procedures described above. No additional areas of risk exist and therefore, no other procedures are necessary at this time.
Click Here to view LIBERTY RESERVE’S Anti-Money Laundering Policy.