1. Policy Statement
0x Agency LLC is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We have implemented robust procedures to prevent our services from being used for illicit purposes.
2. Regulatory Framework
This policy is designed to comply with:
- Bank Secrecy Act (BSA) and USA PATRIOT Act;
- Financial Crimes Enforcement Network (FinCEN) regulations;
- Office of Foreign Assets Control (OFAC) sanctions;
- State and federal AML requirements;
- International best practices including FATF recommendations.
3. Customer Due Diligence (CDD)
3.1 Identity Verification
All clients must undergo identity verification before onboarding, including:
- Full legal name verification;
- Government-issued identification;
- Proof of address (utility bill, bank statement, etc.);
- Date of birth and nationality confirmation;
- Business registration documents (for entities).
3.2 Enhanced Due Diligence (EDD)
We apply enhanced scrutiny for high-risk clients, including:
- Politically Exposed Persons (PEPs);
- Clients from high-risk jurisdictions;
- Businesses with complex ownership structures;
- Large transaction volumes or unusual patterns;
- Industries with elevated AML risk.
4. Ongoing Monitoring
We continuously monitor client activity for:
- Unusual transaction patterns or behaviors;
- Changes in business operations or ownership;
- Sanctions list updates (daily screening);
- Negative news or adverse media;
- Red flags indicating potential financial crime.
5. Sanctions Compliance
We screen all clients against:
- OFAC Specially Designated Nationals (SDN) List;
- United Nations Security Council Sanctions;
- European Union Sanctions Lists;
- Other relevant international sanctions programs.
We do not onboard or maintain relationships with sanctioned individuals, entities, or those in restricted jurisdictions.
6. Suspicious Activity Reporting
If we identify suspicious activity, we will:
- File Suspicious Activity Reports (SARs) with FinCEN as required;
- Maintain confidentiality of all reporting;
- Preserve relevant documentation;
- Cooperate fully with law enforcement;
- Not tip off the subject of investigations.
7. Record Retention
We maintain records for a minimum of five (5) years, including:
- Client identification documents;
- Transaction records and communications;
- Internal investigation findings;
- Compliance monitoring reports;
- Training records for staff.
8. Red Flags
Indicators that may trigger additional scrutiny:
- Reluctance to provide identifying information;
- Use of shell companies or complex ownership structures;
- Transactions inconsistent with stated business purpose;
- Sudden changes in transaction patterns;
- Requests for unusual payment methods;
- Operations in high-risk jurisdictions;
- Involvement in sectors prone to financial crime.
9. Training & Awareness
All personnel receive regular AML training covering:
- Identification of money laundering typologies;
- Sanctions compliance procedures;
- Internal reporting mechanisms;
- Updates to regulatory requirements;
- Case studies and best practices.
10. Compliance Officer
Our designated AML Compliance Officer is responsible for:
- Overseeing the AML program;
- Ensuring regulatory compliance;
- Conducting internal audits;
- Liaising with regulators and law enforcement;
- Reporting to senior management and board.
11. Refusal of Service
We reserve the right to refuse or terminate service if:
- Client fails to provide required documentation;
- We cannot adequately verify identity;
- Client is on a sanctions list;
- Suspicious activity is detected;
- Client operates in a prohibited jurisdiction;
- Relationship poses unacceptable AML risk.
12. Policy Updates
This policy is reviewed annually and updated as needed to reflect changes in regulations, industry best practices, and our business operations.
13. Contact
For AML-related inquiries:
Compliance Officer
0x Agency LLC
30 N Gould Street Ste 40042
Sheridan, WY 82801 USA
📧 compliance@0x.agency