Compliance Policy
Last updated: 30 July 2018

Introduction

ADAX Exchange – an online portal powered by Arabtizor holdings Inc.including its affiliates and subsidiaries are committed to protecting our customers and business environment always with highest level of international practices and standards of compliance in terms ofAnti-Money Laundry (AML), Know Your Customer (KYC), Counter Financing of Terrorism (CFT), Combat Financial Crimes (CFC) and related illegal activities’ in due diligence to prevent any potential overseas instancesrisk maythreatour businessand commercial interests over the offered services and products, therefore, we keep assessing the efficiency of our compliance policies continuously through our applied strict verification and screening levels such as verifying customer’s real identities along with international sanctions and blacklists, moreover to apply ongoing screening for our customers status changes which supported by industry leaders auditing softwareaccording to multiple analysis parameters, regular audit, risk alerts and escalation levels starting from identity verification, ongoing screening of current database, monitor and analyze unusual or suspicious transactions, internal auditingover periodic examination rounds and regular reporting procedures such as Suspicious Transactions Reporting (STR), Currency Transaction Reporting (CTR), Suspicious Activity Reporting (SAR), and up toreaching highest level of escalation by communications with regulators and provide required reporting accordingly.

We prepared our AML policy as a part of the comprehensive Compliance Policy to ensure the highest possible voluntary compliance under national and international standards and procedures which recommended in the guidelines forbest practices by universal authorities such as Financial Action Task Force (FATF)effortsto implement best practices in industrythat meets regulatory requirements andbest business practices.This Compliance Policy applies uniformly to any user desirous of availing ourservices or otherwise using our platform or benefitting from the use of any technology solution become available over our Website(s). It is imperative that you read this Compliance Policy before using any service or product available for you by this Website. By using our Website(s) and services, you are expressly consenting to be bound by the Terms of Service, Privacy Policy and consequently this Compliance Policy. You must stop using our services and productssuch as website(s), platform(s), application(s), software(s) or any other technology solutionwe offer if your use results in committing/attempting to commit any criminal offences.

We have the right, at any time, to change or modify our Compliance Policy terms applicable to your use for any of our services and products, or to impose new terms and conditions, including, but not limited to, additions, deletions or modifications shall be effective immediately upon notice thereof, this notice may be given by means including, but not limited to, updating the “Last Updated” field at the top of this document with the date of the current revision. Any use of our services and products by you after such notice shall be deemed to constitute acceptance by you of such changes, deletions, modifications or additions. Any amended terms will apply prospectively to use of the services after such changes become effective, hence, it is important therefore that you review our updates on a regular basis to ensure that you are familiar with the terms in force from time to time and any changes made to them. If you do not agree to any updates, you must discontinue using our services or products and contact us to terminate your account/registration or any kind of business relationship might be established between you and Arabtizor holdings Inc or any of its subsidiaries, affiliates and partners. We may regularly furnish regulators or law enforcement agencies the details of any transactions taking place intoourwebsite(s), platform(s), application(s), records or any technology solution we may make available for customers and that as deemed necessary by us.

Risk Management Solutions

We are committed to apply best practices in industry in terms of our efforts to undertake the role of risk management and assessment over our services and products to prevent any criminal or suspicious behaviors from being a part of our healthy business environment, hence, we will implement a risk assessment process based on all (or) any of below measures:

  • Sufficiency and adequacy of identification documents submitted by you in any stage of service we choose before the actual delivery of the services or products.
  • Your social and/or financial status if such requirements raised by regulators locally or internationally.
  • Nature and other similar information about your business and/or vocational activities.
  • Guidance notes circulated by various governmental and/or inter- governmental organizations.
  • Any other parameters may be required to perform our operations in best practices.

Important: If you violate any of our Compliance Policy terms at any time or by any mean such as-without limitation- hiding any real information, doesn’t commit to our AML policy requirements or any action might classified as a violation to our Compliance Policy, meanwhile we may use third party software, records or materials to proceed our operations and verification process, herein you understand and agree that we have the full right to reject, suspend, freeze, report your account and its transactions completely upon our steering committee decision and/or regulators regulations, meanwhile, in such case(s) -without limitation- you agree to accept this action against you without any liability toward Arabtizor Holdings Inc. or any of its subsidiaries, affiliates, partners, management, staff members and without objection by you or any party can act on behalf of you.

Categories of Risk Assessment

A part of our procedures to enable evaluating the risk accompanied by the nature of our business users, we may categorize your account into specific risk criteria’s according to one of the following pools:

  • Low-Risk Accounts;
  • Medium- Risk Accounts;
  • High-Risk Accounts.

We will keep your risk categorization and related data confidential at all times, subject to any requests received from a competent law enforcement authority. In order to maintain the integrity of the risk assessment process, the results of your risk assessment and/or categorization will not be disclosed to you either.

Levels of Risk Assessment

We are applying user-friendly process to enable our customers receive our service(s) and product(s) in best way, meanwhile, its inherent a very strict process and procedures to enable us perform due diligence verification process toward our customers real identities and their eligibility of our services and products:

  • New Accounts: this level we don’t ask any additional information from you (except your email address) to ease your ADAX joining process for first level of registration seamlessly, that we need the information just to register your account into our records to enable us proceed further for advanced verification and screening process, given that we apply three levels of registration should be processed respectively and so-called ”Types of Account” as following levels:
    • General Account: which is the first level of account types for any registration to start receive our services;
      • General account requires only an email address to register into our database.
      • General account limitations are:
        • Trading assets: Cryptocurrency to Cryptocurrency trades only;
        • Withdrawals & outgoing transfers: USD 10,000 per month in equivalent (subject to account activation;
        • Deposit & incoming transfers: no limitation.
    • Standard Account: which is the second verification level of account types upgrade in the registration process to receive our services;
      • Standard account requires the requirements: (in addition to A terms)
        • Full Name;
        • Personal Data;
        • Proved Address;
        • Source of Funds;
        • Profession Details;
        • Mobile Phone Number;
        • Bank Account Details (The beneficiary must be same account holder);
        • Supporting Documents such as Passport Copy, National ID, Driving License, Utility Bill, Bank Statement and any additional required documents);
        • KYC questionnaire.
      • Standard account limitations are:
        • Trading assets: Cryptocurrency to Fiat trades and vice versa;
        • Withdrawal & outgoing transfers: USD 100,000 Equivalents per month;
        • Deposits & incoming transfers: no limitation.
    • Business Account: which is the highest verification level of account types upgrade in the registration process to receive our services as corporate account or High Net Wealth Individual (HNWI);
      • Business account requirements: (in addition to B terms)
        • Annual Income Proof;
        • Source of Funds Proof;
        • Advanced Personal Details;
        • Advanced Business Details;
        • Business Shareholders Proof.
        • Supporting Documents such as Certificate of Incorporation, Commercial License, Memorandum of Association, Article of Association, Delegation Letter, Business Utility Bill, Bank Statement and any additional required documents);
        • KYC questionnaire.
      • Business account limitations are:
        • Trading assets: Cryptocurrency to Fiat trades and vice versa;
        • Withdrawal & outgoing transfers: USD 500,000+ Equivalents per month;
        • Deposits & incoming transfers: no limitation.
  • Existing Accounts: we apply regular and periodical auditing and on-going screening role to monitor our customers’ database according to several risk management parameters by analyzing customer’s transactions and behaviors and sort out any suspicious or unusual transaction or mismatch along with expected behaviors, transactions, volumes, count, type or other on-going measures, that is, to make sure of the efficient monitoring procedures followed upon adopted escalation process which being processed and reported to next escalation level to act accordingly and based on applicable standards and practices and regulatory requirements and guidelines. If your risk assessment – at any point of time- didn’t pass our minimum level of security parameters, our applicable AML and KYC standards and requirements, then you understand and agree that we have the full right to reject/close/suspend your account and/or transaction completely and a refund process of your balances will be initiated consequently (if any available balances and subject to not receiving claims by enforcement authorities) that shall be over same original payment channels or otherwise upon our steering committee decision and after deducting the transferring fees and any other operational fees, while in such case(s) -without limitation- you agree to accept this action against you without any objection by you or any party can act on behalf of you, because it’s your sole responsibility to evaluate in advance your identity verification status and its changes if it is being under any restrictions or sanctions lists which might cause this action by default while you are dealing with counterparty implementing high level of international compliance standards especially in terms of AML and KYC requirements.

Identity Verification Procedures

  • Stage one of the default registration into ADAX Exchange is considered “General Account” type which is not verified level and you have to provide all required information and documentations to complete your registration and upgrade process to verified your account type to be able to utilize additional trading, withdrawal and transferring facilities, that will help us to apply our Compliance Policy and facilitate the other supplementary services accompanied with your account, meanwhile periodically for purposes of updating our records and on-going due-diligence practices, then users are required to update their accounts information and documentations upon request – or if expired or changed- as a part of our commitment to keep up-to-date records and proper database, otherwise, we have the right to suspend the account and/or any outstanding transaction until the required update process being completed and approved by our end, noting that required update doesn’t guarantee the eligibility of same account level at all times if was not met our requirements and/or any regulations updates, meanwhile you must promptly update us of any changes to the customer information and/or documents provided to us within three days of effecting such changes.
  • Our Compliance Policy principles indicating explicitly that completed application to register/upgrade your account with ADAX Exchange doesn’t necessary mean or guarantee the final approval by us to register/upgrade your ADAX account and although if the user provided all required information and documents requested for the purpose of identity verification, its known and pre –agreed that final approval to register/ upgrade any ADAX Exchange’s account is our own decision upon our sole discretion which depending on several international standard and practices we implement in favor of our full commitment toward applicable instructions, regulations, rules, practices..etc, hence, we are not obliged to provide any justification for the user if his account registration/ upgrade was rejected or suspended for further notice according to any applicable updates in regulations or laws or even our terms of services.
  • By submitting your request for any of our services and/or products, you authorize us to do all necessary checking process to verify your real identity over any internal process or any government or sanction lists wherever and whenever we find it necessary under any process category or service level. so we may require you to furnish additional details and documents as may be deemed necessary to verify your identity or request validity if we either (i) cannot verify your identity, or (ii) have a reason to believe that you are a person or entity whose details are provided in any official, governmental or intergovernmental sanction list, or (iii) have a reason to believe that you are performing suspicious activity or illegal transaction(s).
  • We implement identity verification and ongoing screening procedures to monitor, analyze and flag customer transactions for review, for instance, the transactions involved maybe exceed our internal limits, limits specified by local or applicable laws, official guidelines, or industry best practices such as -without limitation- account categories remarks. In addition to the above, we are regularly monitor, through both manual screening and use of software-based systems, all transactions executed and/or attempted to be executed on our website(s), platform(s), applications(s) or any technology solution we offer to customer, in order to promptly identify and highlight any suspicious activity, which includes without limitation, activities that:
    • appear, to a person acting in good faith, akin to collection of funds to be used, either in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts;
    • appear, to a person acting in good faith, to have been structured in a manner of unusual or unjustified complexity in order to avoid triggering any reporting requirements;
    • appear, to a person acting in good faith, to have been transacted for suspicious or malafide purpose or where a sound economic rationale cannot be;
    • appear, to a person acting in good faith, to signal possible ‘money-laundering’ activities, as defined under applicable laws;
    • appear to be unusual due to the reason of being inconsistent with any User’s risk profile, expected usage pattern or sophistication. The extent of monitoring shall depend on various factors including upon each User’s risk parameters;
    • any other incident may be raised by our risk management systems requires such action.
  • On detection of any suspicious activity, we reserve the right to take appropriate actions without any prior notification to the User, which includes, without limitation, (i) cancel purchase transaction and suspend transferring process, (ii) terminating ADAX Exchange Account, (iii) restricting and/or blocking further access to our Website(s) and/or ant of our services, and (iiii) notifying the appropriate enforcement authorities regarding the suspicious activities of any User.
  • We reserve the right to refuse registration or transaction to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time without justification behind this termination. Without limiting the generality of the foregoing, this includes, but is not limited to, any party from or in jurisdictions that do not meet our international standards to keep highest level of professional and healthy environment can comply with applicable Terms of Service and its updates, any party that is a Politically Exposed Person (PEP), anyone on an official, governmental or intergovernmental Sanction Lists, upon reasonable request or direction of a competent enforcement authority, or anyone that fails to meet any customer due diligence standards, requests, or requirements of Arabtizor holdings Inc and/or ADAX as our subsidiary online portal.
  • If we believe any information obtained from the User is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; or (d) appearing on any Sanctions Lists, we may in our sole discretion either refuse or terminate (as the case may be) the registration and/or transaction by require such User to verify the Valid Documents submitted by it again and/or provide additional information/documents to enable us validate the registration/transaction. We may also, in our sole discretion, terminate existing User Accounts after giving due notice, or refuse to process any transactions if we are unable to verify any information due to non-cooperation by the User and breaching the notice timelines, or if such transactions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.
  • We may also require you to certify that your Linked Bank Account is held only with a scheduled commercial bank which is compliant with all know your customer (KYC) procedures mandated under the applicable laws. For this purpose, we may require you to furnish this certification in such format as may be prescribed by us, meanwhile, our Compliance Policy restricts any “shell banks” transactions any if any transaction detected at any time and for any reason pertaining to such transactions category, then we have the right to reject, suspend or terminate your relationship with us after reporting such breach to breach.
  • We don’t accept trading delegations on behalf of original account holders for individual accounts and it’s restricted for the corporate accounts only under the Business Account verification level. Furthermore, no third-party payments accepted in customer account of USD suffix or other traditional currencies’ suffixes which might be used later such as EUR, GBP...etc.
  • In case of a legal entity, you must identify the Beneficial Owner(s) and also assist in verification of the identity of such Beneficial Owner(s) and any individual who purports to act on behalf of such legal entities. In this regard, a “Beneficial Owner” means: (A) In case of companies, the natural person who has ownership of over 25% (twenty five percent) of the shares, is entitled to over 25% (twenty five percent) of the profits, or has the power, directly or indirectly, to appoint or elect more than half of the board of directors of such company, as the case may be; and, (B) In case of partnership firms/Limited Liability Partnerships, the natural person(s) who has ownership of over 15% (fifteen percent) of the capital or is entitled to over 15% (fifteen percent) of the profits of such firm, as the case may be.
  • For the purpose of this Compliance Policy and our Terms of Service, “Sanction Lists” are lists available to check individual and entities identities to prevent any unauthorized suspicious exposures and potential illegal activity.
  • Our Compliance Policy is a part of our Terms of Service agreement and shall not be separated by any mean for the Terms of Service.

Delegation to check identity

We may, at our sole discretion at any time, request one or more appropriate third-party service provider to assist us in authentication and verification of the Valid Documents, transactions and other incidental details provided or by you. In addition to the above, we reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We may use the following non-documentary methods of verifying identity partially or completely: (a) Confirming validity of email; (b) Confirming validity of telephone number or bank account number; and (c) Confirming your location using, among others, your IP address or any other mean we might find it appropriate, all of which may be carried out by an automated or manual process and for any account category we see as appropriate.

Records Retention

Under applicable Laws, Standards or practices, we are required to maintain and preserve the following information and/or data:

  • Records of all accounts and transactions executed by you on our Website(s), platform(s), application(s) or any technology solution we make it available for the customer use, for a period of time specified by ten years from the date of each.
  • Records of all suspicious transactions, trans-national transactions, and transactions wherein the amounts involved exceed a specific amount(s), whether executed or attempted, for a period of at least ten years, including but not limited to the information about the nature and value of the transactions, parties involved in such transactions, and information about the date of remittance, in addition to reporting the same upon requested.
  • Identification records of Account Users, including, but not limited to, the Valid Documents submitted, during the subsistence of and for a period of time specified by law from the date of termination of such User’s.
  • Disclosure

    In order to improve the integrity and transparency of transactions over our Online Services, you are encouraged to report, to our Compliance personnel, any information which you are privy to or become privy to, regarding any suspicious transactions, or transactions you find or have reason to believe are dubious in nature.

    In order to ensure full commitment to this Compliance Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as email address provided by you will be considered the main and legal contacting channel to notify you in addition to the website(s) updates. For any further details regarding our Compliance Policy, cordially contact our Compliance Desk at: [email protected]