Client Acceptance Procedure and Anti-money Laundering Compliance Program

Thanks for visiting AMDAX, a digital asset platform operated by and proprietary to AMDAX B.V. (“we” or “our”). We have developed a Client Acceptance Procedure and Anti-money Laundering Compliance Program (“CAP/AML Program”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the Netherlands and other countries where we conduct business. This includes, but is not limited to:

• Establishing robust internal policies, procedures and controls that combat any attempted use of AMDAX for illegal or illicit purposes and that are designed to ensure our customers basic protections under consumer protection laws;
  
• Complying with the applicable regulations and guidance set forth by the Dutch Law (“Wet ter voorkoming van witwassen en financieren van terrorisme”, in short “Wwft”);
• Do Transaction Monitoring;
• Oblige to our reporting duty aimed at preventing money laundering and terrorist financing;
• Maintaining comprehensive records of orders and other transfers;
• Employing a Compliance Officer (“CO”) and be responsible for the implementation and oversight of our CAP/AML Program;
• Executing Know Your Customer (“KYC”) procedures on all customers;
• Performing regular, independent audits of our CAP/AML Program;
• Following record retention requirements; and
• Implementing a formal and ongoing compliance training program for all new and existing employees.

Policies and Procedures

Our CAP/AML Program has been reviewed and approved by our Board of Managers (the “Board”). Our CAP/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. We are registered with the Dutch Central Bank (de Nederlandsche Bank) and our CAP/AML Program is subject to its review and approval.

Internal Controls

We have developed internal policies, procedures, and controls designed to comply with applicable CAP/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Client Research Policy (“CRP”), adhere to Sanction Regulations and adhere to the Client Monitoring & Transaction Monitoring policies, as well as other reporting requirements and audits.

Training

All of our employees and officers receive ongoing broad-based CAP/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

Compliance Officer

Our CO is responsible for developing and enforcing the policies and procedures of our CAP/AML Program. Our CO is required to report any violations of our CAP/AML Program directly to our Board. In addition, our CO is responsible for recording and filing monitoring data with the regulator performing a CAP/AML Program audit at least annually.

Customer Identification

Our Client Research Policy (“CRP”) is an important part of our CAP/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

Account Opening Process

In order to open an account and use AMDAX, your identity must be verified, authenticated, and checked against government watchlists. Failure to complete any of these steps will result in your inability to use our platform.

Individual customer

Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:

• Email address;
• Mobile phone number;
• Full legal name;
• Social Security Number (“SSN”) or any comparable identification number issued by government;
• Date of birth (“DOB”);
• Proof of identity that includes nationality (passport or government-issued ID);
• Home address (not a mailing address or P.O. Box);
• Proof of address (e.g., electric, gas or water bill) and
• Additional information or documentation at the discretion of our Compliance Team.

If you successfully meet and complete our CRP requirements and do not appear on any watchlist, then we will provide you with account opening agreements electronically.

Institutional customer

Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:

• Institution legal name;
• Employer Identification Number (“EIN”) or any comparable identification number issued by government;
• Full legal name (of all account signatories and beneficial owners);
• Email address (of all account signatories);
• Mobile phone number (of all account signatories);
• Address (principal place of business and/or other physical location);
• Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license or other comparable legal documents as applicable);
• Contract information of owners, principals, and executive management (as applicable);
• Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
• Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).

If your institution successfully meets and completes our CRP requirements and neither it nor any of its owners, principals, executive, or managers appear on any watchlist, we will provide you with account opening agreements electronically.

Suspicious Activity/Currency Transaction Reports Opening Process

We file suspicious activity reports if we know, suspect or have reason to suspect suspicious activities have occurred on ADMAX. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our CO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a report.

In addition, all currency transactions over a determined euro value are be reported to Dutch Financial Intelligence Unit (“FIU”).

Our CO maintains records and supporting documentation of all filed reports.

Reporting Requirements

All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

BSA/AML Program Audit

The CO is responsible for performing an audit of our CAP/AML Program at least annually and presenting the results to the Board.