AML Policy
Background Information
1. Main Objectives
2. General Principles
Anti-Money Laundering Policy
Customer Due Diligence ('CDD')
Suspicious Transactions
Training
Record-Keeping
3. Our Responsibilities
4. Risk-Based Approach
Client Characteristics, Product, Service, Delivery Channel:
Geography:
Other Suspicious Transaction Indicators:
5. Indicators of Suspicious Transactions or Potential High-Risk Clients
General Indicators:
Industry-Specific Examples:
6. Data Request
7. Restricted Activities and Clients
Private Individuals with the Following Characteristics:
Legal Persons with the Following Characteristics:
A High-Risk Client is Someone:
8. Sanctions
9. List of Non-Serviced Countries
10. Monitoring for Suspicious Activity
Contact Information
CoinCircuit is committed to maintaining effective crime prevention and detection measures to assist law enforcement agencies in combating financial crime. We have adopted a strict set of policies and procedures to fulfil our legal obligations under international anti-money laundering and anti-terrorism legislation.
Money laundering is a process by which money and property (assets) obtained as a result of criminal activity are disguised as coming from a legitimate source. In essence, money laundering is a process in which "dirty money" obtained through criminal activity turns into "clean money", the criminal origin of which is difficult to trace.
There are three recognized stages in the process of money laundering:
Money laundering starts with the proceeds of crime from the predicate offence. Predicate offences include tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeiting, securities manipulation, and copyright infringement, among others.
Terrorist financing is when you knowingly collect or provide property, such as money, directly or indirectly to terrorists. The main purpose of terrorist activities is to intimidate the public or to force government action. Terrorists need financial support to carry out terrorist activities and achieve their goals. Many of the techniques used for money laundering are also used in terrorist financing, including but not limited to concealing the channelling of funds and the use of third parties.
CoinCircuit has implemented policies, procedures and controls designed to prevent criminals from using our platform to launder the proceeds of crime. These policies and procedures are tailored to the risk posed to individual customers.
CoinCircuit has established customer due diligence procedures to identify the users of its services and, in respect of higher risk customers, the primary beneficial owners and origin of funds. These procedures include knowledge of the nature of our customers' business and vigilance for anomalous transactions.
In general, the CDD policy has been adopted by CoinCircuit to successfully fulfil the following objectives:
CoinCircuit is strictly prohibited from keeping anonymous accounts or accounts in fictitious names.
Unexplained or anomalous transactions or activities suspected to be related to criminal activity should be reported immediately in writing to the Compliance Officer, who will determine whether the suspicion should be reported to Law Enforcement.
All personnel must be informed of their individual and collective responsibilities and CoinCircuit's anti-money laundering policies. Personnel are provided with training to enable them to understand the vulnerabilities of CoinCircuit's business and to recognize and report suspicious activities.
CoinCircuit keeps records of who has been trained and the time and form of the training sessions. We keep all records confirming the identity of our customers for at least 7 years after the end of the business relationship. We also keep records of any internal reports of suspicion made to the Compliance Officer.
All cryptocurrency payment service providers are required by International Law to:
Risk can be defined as the likelihood of an event and its consequences. In the context of money laundering/terrorist financing (ML/TF), risk means:
All clients default to low risk, UNLESS risk factors are present. Automatic high-risk characteristics include:
The following are examples of general and industry-specific indicators that may give you reasonable grounds to suspect that a transaction involves money laundering or terrorist financing. The presence of one or more of these factors does not automatically mean that the transaction should be reported, but it does indicate that a more in-depth examination is required.
To mitigate the risks associated with money laundering and terrorist financing, we strictly do not accept or send payments to third parties (unidentified). Each customer may only send and receive payments through their own accounts, including cryptocurrency wallets, bank accounts, and payment system accounts.
In accordance with KYC ("Know Your Customer") policy, our employees are authorised to carry out customer verification. In this case, the customer is required to provide the following information:
We reserve the right to refuse to process a transaction at any stage if it is suspected to involve money laundering or other criminal activity.
To mitigate and control ML risk related to clients, CoinCircuit does not provide services and refuses account opening for the following clients with unacceptable risk levels:
In accordance with internal AML/CFT procedures, CoinCircuit has customers in two risk categories - low-risk and high-risk customers. For high-risk customers, Enhanced Due Diligence (EDD) should be carried out.
CoinCircuit is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. CoinCircuit will therefore screen against the relevant sanctions lists in the jurisdictions in which we operate.
CoinCircuit has no AML Risk Appetite for establishing or maintaining a customer or counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation:
In addition, CoinCircuit pays particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.
CoinCircuit does not open accounts and does not provide services to clients from the following countries and jurisdictions:
Note: CoinCircuit does not on-board US persons or entities. We adopt the list of high-risk countries as released by local and foreign regulatory authorities from time to time.
CoinCircuit's AML policy includes customer and beneficial owner due diligence, ongoing AML monitoring and AML reporting policies. At various points in time, CoinCircuit may request information regarding the transactions carried out through the customer's account and the parties of the respective payment.
If the customer does not respond sufficiently or within a timely manner, CoinCircuit reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.
If you have any questions about our AML Policy or need to report suspicious activity, please contact our Compliance Officer:
Last Updated: November 10, 2025
Afghanistan, Balkans, Belarus, Bosnia
Central African Republic (CAR), Crimea, Cuba
Democratic Republic of Congo (DRC), China
Eritrea, Guinea-Bissau, Haiti
Iran, Iraq, Ivory Coast, Lao
Lebanon, Liberia, Libya, Mali
Moldova, Myanmar (Burma), Nicaragua
North Korea, Pakistan, Republic of Guinea
Russia, Serbia/Yugoslavia, Somalia
Sri Lanka, South Sudan, Sudan, Syria
Trinidad & Tobago, Ukraine, United States
Vanuatu, Venezuela, Yemen, Zimbabwe
CoinCircuit Limited
compliance@coincircuit.io
legal@coincircuit.io
Placement: Involves the placement of proceeds from crime in the financial system.
Layering: Involves the transformation of proceeds of crime into another form and the creation of complex layers of financial transactions to complicate the audit trail and hide the source and ownership of the proceeds.
Integration: Involves the return of laundered income to the economy to create an idea of legitimacy.
Clients' identities are satisfactorily verified in accordance with our risk-based approach before CoinCircuit does business with them
CoinCircuit knows its clients and understands their reasons for doing business with us both at the client acceptance stage and throughout the business relationship
Our staff are trained and made aware of both their personal legal obligations and the legal obligations of CoinCircuit
Our staff is trained to be vigilant for activities where there are reasonable grounds for suspicion that money laundering could be taking place and to report to the Compliance Officer
Sufficient records are kept for the required period
We establish, maintain and implement appropriate procedures to achieve these objectives
Identification and verification of the applicant for business
Identification and verification of the beneficial owner, where applicable
Identification and verification when the applicant for business does not act as principal
Obtaining information on the purpose and intended nature of the business relationship
Conducting ongoing monitoring of the business relationship
Establishing the source of wealth and source of funds
Setting up of a customer acceptance policy and ensuring that the applicant for business meets the requirements set out in such policy
Develop a programme to ensure compliance with reporting, record keeping and customer identification requirements
Comply with customer identification rules and maintain specific records for specific transactions
Report suspicious transactions, large cash transactions and information related to terrorist property
At the national level: ML/TF threats and vulnerabilities that jeopardise the integrity of the financial system
At the Company level: Threats and vulnerabilities that put CoinCircuit at risk of being used to facilitate ML/TF
Politically exposed person
A client where a suspicious transaction or terrorist financing report has been filed
A client who is an identified terrorist
A client for whom we are unable to obtain beneficial ownership information
A client from high-risk country
Politically exposed person, head of international organization and close associates
Unknown source of funds
Large transaction orders from/to high-risk foreign jurisdictions
Third party involvement without reasonable justification
Occupation – High-risk occupations (e.g., cash intensive businesses, offshore business, business in high-risk countries, online gambling)
Client's business structure or transactions seem unusually complex
Non face-to-face client identification without justifiable reason
Client resides outside local or normal client area
Client resides in known crime area
Client has offshore business activities
Client connections to high-risk countries
Volume/timing/complexity of transactions inconsistent with the client's personal/business activity and/or purpose of the services/account
Value of deposits/transfers inconsistent with occupation or source of funds
Presence of any suspicious transaction indicators outlined in the Background Information section
Client admits to or makes statements about involvement in criminal activities
Client refuses or tries to avoid providing information required, or provides information that is misleading, vague, or difficult to verify
Client produces seemingly false documentation that appears to be counterfeited, altered or inaccurate
Client appears to have accounts with several financial institutions in one area for no apparent reason
Client repeatedly uses an address but frequently changes the name involved
Client shows uncommon curiosity about internal controls and systems
Client presents confusing details about the transaction
Client makes inquiries that would indicate a desire to avoid reporting
Client is involved in unusual activity for that individual or business
Client seems very familiar with money laundering or terrorist activity financing issues
Client refuses to produce personal identification documents
Client frequently travels to a high-risk country
Client requests cryptocurrency exchanges at rates that exceed posted rates
Client wants to pay transaction fees that exceed posted fees
Client exchanges currency and requests the largest possible denomination in cryptocurrency
Client knows little about recipient wallet address and contact details, or is reluctant to disclose this information
Client enters into transactions with counterparties in locations that are unusual for the client
Client instructs that funds are to be picked up by a third party on behalf of the payee
Client makes large cryptocurrency purchases inconsistent with known business plans
Client makes purchases in large volumes without clear business justification
Information about the services for which the funds were received
Documentation confirming the receipt and withdrawal of funds
Additional information that may be requested
Information of negative nature is available about the client, indicating their possible relation to proceeds of crime, money laundering or terrorism
Client funds have previously been frozen or arrested in connection with suspected criminal activity
Client is trying to avoid provision of information or trying to hide their economic activity
Trafficking in arms and ammunition
Unlicensed foreign currency exchange intermediary services (such as forex dealers, binary options), as well as other unlicensed investment services
Escort services organization/activities and/or distribution of erotic/pornographic videos and pictures
Cash collection services
Debt recovery services
Drug distribution and controlled substances
Pyramid schemes and multi-level marketing
Telemarketing
Pawnshop services
Tobacco and alcohol products distribution
Information of negative nature is available indicating possible relation to proceeds of crime, money laundering or terrorism
Unlicensed reinsurance services with lack of proper supervision
Investment services when the service provider is not properly licensed
Legal entities which are recognized as shell companies
Unlicensed gambling services organization
The reason for the legal entity's establishment is unclear and information about economic objectives are vague and ambiguous
Unlicensed foreign currency exchange intermediary services
Client's transactions or payments are complex, unusually large or unclear in terms of their legal and economic objective
Who is a politically exposed person, their family member or a close associate
With whom financial claims and either arising out of or related obligations exceed $10,000 USD
Sanction lists administered by the United States Office of Foreign Assets Control (OFAC)
The United Nations Security Council Sanctions List (UN)
The Consolidated List of European Union Financial Sanctions (EU)
List of Specially Designated Nationals and Blocked Persons
Any other applicable sanctions lists
Company Name: CoinCircuit Limited
Registered Address: Nigeria
Compliance Officer: compliance@coincircuit.io
Legal: legal@coincircuit.io