Introduction

X Change Financial Services Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of the Company being involved in any kind of illegal activity. International and local regulations necessitate that the Company implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users. The Company takes this business very seriously and has a zero tolerance policy for abusers.

AML/KYC Policy covers the following:

• Verification procedures
• Compliance Officer
• Monitoring Transactions
• Risk Assessment

1. Verification procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). Specific to these principles, X Change Financial Services has established its own verification procedure within the standards of anti-money laundering and “Know Your Customer” frameworks.

1. a. Identity verification XCFS’s identity verification procedure requires the User to provide the Company with reliable, independent original color copy source documents, data or information (examples include: national ID, international passport, bank statement, utility bill). XCFS will take steps to confirm the authenticity of documents and information provided. All legal methods for confirming identification information will be used and XCFS reserves the right to investigate certain Users who have been determined to be of a higher risk. XCFS reserves the right to verify and update User’s identity on an on-going basis, especially when their identification information has been changed or their activities change and become unusual for a particular user. In addition, XCFS reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past. User’s identification information will be collected, stored, shared and protected strictly in accordance with the myxpay’s Privacy Policy and related regulations. Once the User’s identity has been verified, XCFS is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
2. b. Card verification

The Users who are intending to make a payment to XCFS must pass our payment verification process in accordance with instructions available on myxpay Site.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by XCFS, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of XCFS’s anti-money laundering and counter-terrorist financing, including but not limited to:

• Collecting Users’ identification information.
• Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
• Monitoring transactions and investigating any significant deviations from normal activity.
• Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
• Updating risk assessment regularly.
• Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

3. Monitoring Transactions

System Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, in certain cases, XCFS will rely on data analysis as a risk-assessment and suspicion detection tool. XCFS will perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

System functionalities include:

• a. Where new customers are concerned, Check of Users against recognized “black lists” (e.g. OFAC), place Users on watch and service denial lists, opening “tickets” for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
• b. Case and document management. With regard to the AML/KYC Policy, XCFS reserves the right to monitor all transactions; ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; request system User provide any additional information and documents in case of suspicious transactions; suspend or terminate User’s Account when XCFS has reasonable suspicion that such User engaged in suspicious activity.

The above list is not exhaustive and the Compliance Officer reserves the right to monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

4. Risk Assessment

XCFS, in line with the international requirements, has adopted a risk-based approach to combating money laundering and potential terrorist financing. By adopting a risk-based approach, XCFS is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient way. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.