AML Policy

01Overview

Cointup is committed to maintaining the highest standards of anti-money-laundering ("AML") and counter-terrorist-financing ("CTF") compliance. We operate a risk-based programme designed to detect, prevent and report activity that may involve money laundering, terrorist financing or other financial crime.

02Regulatory framework

Our programme is designed to align with applicable AML/CTF laws and international standards, including the recommendations of the Financial Action Task Force (FATF). We appoint a dedicated Money Laundering Reporting Officer (MLRO) responsible for oversight of the programme.

03Know Your Customer

Before granting access to certain services, we verify the identity of every customer. This includes collecting and validating identity documents, proof of address and other information appropriate to the customer's risk profile.

04Customer due diligence

We apply a risk-based approach to due diligence:

• Standard due diligence for lower-risk customers.
• Enhanced due diligence for higher-risk customers, including politically exposed persons (PEPs) and customers from higher-risk jurisdictions.
• Ongoing due diligence to keep customer information current throughout the relationship.

05Transaction monitoring

We monitor transactions on an ongoing basis using automated and manual controls to identify unusual or suspicious patterns. Where appropriate, we may request additional information, delay or block transactions, or restrict accounts pending review.

06Sanctions screening

We screen customers and transactions against applicable sanctions and watch lists. We do not provide services to individuals or entities subject to sanctions, and we block dealings with restricted parties and jurisdictions.

07Reporting obligations

Where we identify activity that we know or suspect may be linked to financial crime, we file reports with the relevant authorities in accordance with applicable law. We do not "tip off" customers about any report that has been or may be made.

08Record keeping

We retain customer identification records, transaction data and supporting documentation for the period required by applicable law, and make these records available to regulators and authorities on lawful request.

09Training & governance

Our staff receive regular AML/CTF training appropriate to their roles. The programme is reviewed periodically and subject to independent testing to ensure it remains effective and up to date.

10Contact us

For compliance enquiries, contact our team via the contact page or email compliance@cointup.com.