CAP/AML PROGRAMMA / ONBOARDING PROGRAM
Omdat AMDAX zowel Nederlandse als internationale klanten bedient, hebben we onze juridische documenten in het Engels opgesteld. Binnen AMDAX is Engels het uitgangspunt als het om juridische communicatie gaat – de Engelse contracten zijn dus leidend. Indien u vragen heeft over een van de documenten, staan we altijd voor u klaar om deze te beantwoorden – uiteraard (ook) in het Nederlands.
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:
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.
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.
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.
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.
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.
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.
Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:
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.
Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:
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.
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.
All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.
The CO is responsible for performing an audit of our CAP/AML Program at least annually and presenting the results to the Board.