AML & CFT Policy
Our comprehensive framework for Anti-Money Laundering and Combating the Financing of Terrorism to ensure a safe and compliant trading environment.
Make sure you read Cofinex’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policies carefully. This document outlines our commitment to preventing financial crime and ensuring transparency across all transactions.
Principles and Methods of Cofinex AML/CFT Measures
Cofinex is committed to supporting AML/CFT efforts globally. In principle, we are dedicated to conducting business in accordance with high ethical standards and preventing the establishment of any business relationship that could contribute to money laundering or terrorism financing.
Due Diligence
Conducting thorough due diligence when dealing with customers and natural persons appointed to act on their behalf.
Global Cooperation
Assisting and cooperating with relevant legal authorities to prevent the threat of money laundering and terrorism financing.
Risk Assessment
We anticipate that the majority of our customers will be retail customers. Operating primarily in the Republic of Czech, we record and collect documentation on the identity of our customers and their jurisdictions.
Restricted Regions Include:
- Democratic People’s Republic of Korea
- Iran
- Sudan & South Sudan
- Syria
- UN Sanctions Lists (1267/1989/1988)
Risk Mitigation
When identified, we shall not deal with anyone on the list of designated individuals and entities. Our mitigation strategy involves immediate cessation of relations and reporting to relevant authorities.
New Products and Technical Methodology
We provide appropriate notice on the identification and assessment of money laundering and terrorist financing risks that may arise in the development of new products, business practices, or delivery mechanisms.
Approach to Customer Due Diligence (CDD)
Cofinex does not open, maintain, or accept anonymous or pseudonymous accounts. We perform CDD in the following situations:
- When entering into a business relationship with any customer.
- When executing transactions without an established relationship.
- When suspecting money laundering or terrorism financing.
- When doubting the truth or adequacy of provided information.
Customer Identity Verification
We use reliable and independent data to verify identity. For individuals, this includes full names, unique ID numbers (Passport/ID), registered addresses, and date of birth.
Individual Verification
Verification via Government ID, Proof of Address, and Biometric checks.
Legal Entities
Verification of entity type, proof of existence, statutes, and executive powers.
Beneficial Owners
We inquire about and identify the natural persons with ultimate ownership or control over legal persons or arrangements. For legal persons, we identify those with ultimate ownership (typically 25% or more) or ultimate control.
Continuous Monitoring
We monitor business relations on an ongoing basis. This includes reviewing transactions to ensure consistency with our knowledge of the customer's risk profile and source of funds.
Anomaly Detection
Screening for complex, unusually large, or unusual patterns with no apparent economic purpose.
Risk-Based Updates
Regularly updating CDD data, especially for high-risk customers.
Sanctions Tracking
Daily screening against updated international and local sanctions lists.
Non-Face-to-Face Relationships
For non-face-to-face contacts, we implement CDD measures that are at least as stringent as those required for face-to-face contact. This includes using advanced technical solutions to manage impersonation risks.
Record Keeping
Proper records, including CDD information and transaction details, are retained for a period of at least **5 years** from the date of the transaction or termination of the relationship.
Suspicious Transactions Reports (STRs)
We notify relevant authorities and file STRs as required by law. We maintain comprehensive records of all suspicious activities and subsequent reports.
Compliance, Audit, and Training
Cofinex maintains a robust internal compliance structure, including:
- Appointment of a management-level AML/CFT Compliance Officer.
- Independent audit capabilities to test the effectiveness of our Program.
- Regular training for employees to stay updated on AML/CFT matters.
- Enterprise-wide risk assessments across inherent risk, mitigating controls, and residual risk phases.
Have questions about our AML policy?
Our compliance team is here to help you understand our safety frameworks.
support@cofinex.io
