Client Acceptance Procedure and Anti-money Laundering (CAP/AML) Compliance Program

Thank you for visiting AMDAX, a digital asset platform operated by and proprietary to AMDAX B.V. (“AMDAX”, “we” or “our”). We have developed a Client Acceptance Procedure and Anti-money Laundering Compliance Program (“CAP/AML Program”) to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering and sanctions. This program 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 client protection under client protection laws;
• complying with the applicable regulations and guidance set forth by Dutch law (among others the Anti-Money Laundering and Counter-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme) and Sanctions Act (Sanctiewet);
• transaction monitoring;
• our reporting duty aimed at preventing money laundering and terrorist financing;
• maintaining comprehensive records of orders and other transfers;
• appointing a Compliance Officer (“CO”) who is responsible for the implementation and oversight of our CAP/AML Program;
• executing Know Your Customer procedures on all clients;
• 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 Directors (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 in this document. This includes, but is not limited to, our Client Research Policy, Sanction regulations and 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 relevant regulator and performing a CAP/AML Program audit at least annually.

Client Identification and Account Opening Process

Our CRP is an important part of our CAP/AML Program and helps us detect suspicious activity in a timely manner and prevents fraud and anti-money laundering.

In order to open an account and use AMDAX, your identity must be verified, authenticated, and checked against sanction lists. Failure to complete any of these steps will result in you not being granted access to our platform.

Individual

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

• Email address;
• Mobile phone number;
• Full legal name;
• Social security number or any comparable identification number issued by government;
• Date of birth;
• Proof of identity (e.g. driver’s license, passport or government-issued ID);
• Home address (not a mailing address or P.O. box);
• Proof of address (e.g. utility bill or bank statement); and
• Additional information or documentation at the discretion of our Compliance Team.

If you successfully meet and complete our CRP requirements, you may open an account with us.

Company

Prior to opening an account for a company, we collect, verify, and authenticate the following information:

• Company name;
• Employer Identification Number or any comparable identification number issued by government;
• Full legal name of all authorized signatories and ultimate beneficial owners;
• Email address of all authorized signatories;
• Mobile phone number of all authorized signatories;
• Address (principal place of business and/or other registered office);
• Proof of legal existence (e.g. certified articles of association or certificate of incorporation, unexpired government-issued business license or other comparable legal documents as applicable);
• Contact information of ultimate beneficial owners, principals, and executive management (as applicable);
• Proof of identity (e.g. driver’s license, passport or government-issued ID) for each ultimate beneficial owner having a 10% or more interest in the company, as well as all authorized signatories; and
• Identifying information for each ultimate beneficial owner having a 10% or more interest in the company (see individual client information collected above for more details).

If the company successfully meets and completes our CRP requirements, you may open an account with us.

Transaction Monitoring

We continuously monitor all transactions or our clients. We file suspicious activity reports if we know, suspect or have reason to suspect that suspicious activities and/or transactions have occurred on our platform. A transaction may be suspicious if it is inconsistent with a client’s known and legitimate business, personal activities, transaction history, transaction profile or personal means. Our CO is informed of each transaction with a possible integrity risk and determines whether the transaction is suspicious.

In addition, all currency transactions over a determined euro value are reported to the Dutch Financial Intelligence Unit. Our CO maintains records and supporting documentation of all filed reports.

Records

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