Last Revised:   05 October 2021
Coinhako is firmly committed to participating in international efforts to combat money laundering (“ML”) and terrorist financing (“TF”) activities, as well as complying with Anti-Money Laundering (“AML”), Countering the Financing of Terrorism (“CFT”) and Sanctions laws (the “AML Program”), and regulations applicable to the firm.
Coinhako is currently regulated under the Payment Services Act in Singapore as an exempted entity – which allows us to continue our business operations legally in Singapore, until the official licenses under the Payment Services Act are issued. The AML Program consists of, among other things:
  • Robust Governance Framework in which the Board of Directors (the “Board”) and Senior Management provide oversight over the AML Program;
  • Designation of a Money Laundering Reporting Officer (MLRO), who is accountable for the design and operations of the AML Program. The MLRO has unfettered direct access to, and regular communication with the Board and Senior Management, and provides them with regular reports on the operations and effectiveness of Coinhako’s AML Program;
  • Designations of Compliance Officers who are responsible for coordinating and monitoring day to day compliance with the AML Program;
  • AML risk assessments at the AML Program, customer and product & services levels;
  • Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations;
  • Know-Your-Customer standards reasonably designed to identify and verify all customers and, where applicable, beneficial owners, source of funds and the nature and intended purpose of the business relationship, to the extent warranted by the risk of ML or TF or as required by regulations;
  • Enhanced due diligence on higher risk customers, including those who are assessed to be politically exposed persons;
  • Having a combination of risk-based measures and systems for monitoring transaction activity through customers' accounts, and contacting users for additional information as and when necessary, where such information is not available from monitoring and analysis, to ensure compliance with applicable laws, regulations and policies ;
  • Identification and reporting of suspicious activity to appropriate regulatory authorities in accordance with applicable laws;
  • AML training for appropriate personnel;
  • Independent audit to review and assess the compliance with the AML Program;
  • Prohibition from conducting business with certain categories of clients, including but not limited to:
    1. Individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists;
    2. Clients operating in prohibited industries;
    3. Client in which their identity, or beneficial owners cannot be ascertained;
    4. Clients who refuse to furnish information or documents sufficient to satisfy our due diligence;
    5. Clients where the legitimacy of the business cannot be ascertained.
Compliance with our AML Program and internal procedures allows us to maintain good standing in the jurisdictions in which we transact business. Coinhako cooperates to the fullest extent permitted by law with investigations and inquiries from law enforcement and regulatory authorities.