TRY BOT

AML Policy

MatanCoin - a peer-to-peer (P2P) exchange platform offering a marketplace through the telegram messenger for the sale and purchase of digital assets – is registered with the United States Treasure Department’s Financial Crimes Enforcement Network (“FinCEN”) as a Money Service Business (“MSB”). MatanCoin has developed this Anti-Money Laundering Policy (“AML policy”) and internal procedures to prevent money laundering or the funding of terrorist activities and to protect its business and its users from being used in such criminal activities by complying with all applicable requirements of the Bank Secrecy Act (BSA) and FinCEN regulations. Our AML policies and internal procedures will be reviewed and updated on a regular basis to ensure they meet both changes in regulations and changes in our business. We fully cooperate with FinCEN, the U.S. government, as well as any anti-money laundering and terrorist-financing bureaus and organizations.

Complying with BSA and FinCEN regulations, MatanCoin has implemented the following procedures:

  • Appointment of a Chief Compliance Officer ("CCO”) responsible for our AML program who is qualified by experience, knowledge, and training of the BSA and FinCEN regulations.
  • Implementation and completion of a risk-based program Know Your Customer (“KYC”) to document and verify the identity of our customers who open new accounts with us. KYC enables MatanCoin to form a reasonable belief that it knows the true identity of its customers.
  • Implementation and completion of a risk-based program Customer Due Diligence (“CDD”) designed to identify and verify the identities of beneficial owners of legal entity customers, subject to certain exclusions and exemptions.
  • Implementation and completion of a risk-based program Enhanced Due Diligence (“EDD”) designed to investigate certain clients identified as posing a high risk of involvement with money laundering or terrorist financing crimes.
  • Implementation and completion of the Office of Foreign Assets Control (“OFAC”) compliance program performed in conjunction with AML compliance and designed to verify that our customers do not appear on the list of Specially Designated Nationals and Blocked Persons (“SDN list”), which includes names of companies and individuals against whom OFAC enforced economic sanctions or embargoes.
  • Ongoing monitoring of transactions completed by all users for potentially suspicious and attempted suspicious activities.
  • Filing of Suspicious Activity Reports (“SARs”). We will file SARs with FinCEN for any transactions conducted or attempted through MatanCoin Telegram bot where we know, suspect, or have reason to suspect: (i) the transaction involves funds derived from illegal activity or is conducted disguise funds or assets derived from illegal activity, (ii) the transaction is designed to evade any requirements of the BSA regulations, (iii) the transaction has no business or apparent lawful purpose, (iv) the transaction involves the use of MatanCoin to facilitate criminal activity.
  • Maintaining SAR Confidentiality. We will hold SARs and any supporting documentation confidential. We will not inform anyone outside of FinCEN or other appropriate law enforcement or regulatory agency about a SAR. We will refuse any subpoena requests for SARs or for information that would disclose that a SAR has been prepared or filed and immediately notify FinCEN of any such subpoena requests that we receive.
  • Maintaining record keeping procedures. We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer's identity for five years after the record is made. We will retain copies of any SAR filed and the original or business record equivalent of any supporting documentation for five years from the date of filing the SAR form.

 

Maintaining ongoing compliance training for our employees on at least annual basis designed to ensure their understanding of their duties, responsibilities, and record retention policy due to our compliance program, as well as the disciplinary consequences for non-compliance with the BSA.