Anti-Money Laundering Policy

Anti-Money Laundering (AML) Policy

Last Updated: January 2025

DiTokens is committed to preventing money laundering, terrorist financing, and other financial crimes. Our comprehensive AML program ensures compliance with international regulations and maintains the integrity of our platform.

Policy Overview

This Anti-Money Laundering Policy establishes the framework for identifying, assessing, and mitigating money laundering and terrorist financing risks. All employees, contractors, and business partners must adhere to these procedures.

Risk Assessment

We conduct regular risk assessments to identify and evaluate potential money laundering and terrorist financing risks, including:

  • Customer risk profiles and transaction patterns
  • Geographic risk factors and high-risk jurisdictions
  • Product and service risk characteristics
  • Delivery channel risks and technological vulnerabilities
  • Regulatory and legal environment changes

Customer Due Diligence (CDD)

Standard Due Diligence

For all customers, we perform standard due diligence including:

  • Identity verification using government-issued documents
  • Address verification through utility bills or bank statements
  • Source of funds verification
  • Purpose of account and expected transaction patterns
  • Ongoing monitoring of account activity

Enhanced Due Diligence (EDD)

Enhanced due diligence is required for high-risk customers, including:

  • Politically Exposed Persons (PEPs)
  • Customers from high-risk jurisdictions
  • Customers with complex ownership structures
  • Customers with unusual transaction patterns
  • Customers involved in high-risk industries

Transaction Monitoring

We implement comprehensive transaction monitoring systems to detect suspicious activities, including:

  • Real-time transaction screening and analysis
  • Automated alerts for unusual patterns
  • Manual review of flagged transactions
  • Regular reporting to compliance team
  • Documentation of all monitoring activities

Suspicious Activity Reporting

When suspicious activity is detected, we follow these procedures:

  • Immediate investigation and documentation
  • Internal reporting to compliance officer
  • External reporting to relevant authorities
  • Account restrictions or termination if necessary
  • Ongoing monitoring and follow-up

Record Keeping

We maintain comprehensive records of all AML-related activities, including customer identification documents, transaction records, monitoring reports, and suspicious activity reports. Records are retained for the minimum period required by applicable regulations.

Training and Awareness

All employees receive regular AML training covering:

  • Recognition of money laundering indicators
  • Customer due diligence procedures
  • Transaction monitoring requirements
  • Reporting obligations and procedures
  • Regulatory updates and changes

Sanctions Screening

We screen all customers and transactions against international sanctions lists, including OFAC, EU, UN, and other relevant sanctions databases. Matches are immediately escalated for review and appropriate action.

Independent Testing

Our AML program undergoes regular independent testing by internal audit and external compliance experts to ensure effectiveness and identify areas for improvement.

Regulatory Compliance

We maintain compliance with all applicable AML regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, EU Fourth and Fifth Anti-Money Laundering Directives, and other relevant international standards.

Contact Information

For AML-related inquiries or to report suspicious activity, please contact our compliance team:

Email: compliance@ditokens.com
Phone: +971 (9900) 666
Address: United Kingdom