Anti-Money Laundering, Countering the Financing of Terrorism & Sanctions Policy Statement

Last Revised:   15 June 2022
Hako Technology Pte. Ltd (“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, and regulations applicable to the firm. This is collectively known as our AML Program.
The AML Program is designed to ensure Coinhako complies with the abovementioned requirements and obligations set out in the applicable Singapore legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the company being used to facilitate financial crime.
Coinhako is currently regulated under the Payment Services Act in Singapore, and has received an in-principle approval from the Monetary Authority of Singapore for a digital payment token (DPT) service license – 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:
1. AML/CFT and Sanctions Policy
The AML/CFT and Sanctions Policy sets out the minimum standards which must be complied with by us. This includes:
    1. Robust Governance Framework in which the Board of Directors (the “Board”) and Senior Management provide oversight over the AML Program;
    2. 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;
    3. Designations of Compliance Officers who are responsible for coordinating and monitoring day to day compliance with the AML Program;
    4. Risk assessments at the AML Program, customer and product & services levels;
    5. Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations;
    6. Know-Your-Customer (KYC) 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;
    7. Enhanced due diligence for those customers presenting higher risk, including those who are assessed to have Politically Exposed Person (PEP) nexus;
    8. 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;
    9. Procedures to report unusual activities internally, and reporting of suspicious activity to appropriate regulatory authorities in accordance with applicable laws;
    10. Mandatory, periodic AML/CFT and sanctions training for appropriate personnel;
    11. Independent audit to review and assess the compliance with the AML Program; and
    12. The maintenance of appropriate records for the minimum prescribed periods.
Coinhako is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. In addition to the local MAS List, we endeavor to screen against the United Nations (UN), European Union (EU), UK Treasury (HMT), US Office of Foreign Assets Control (OFAC), and other sanctions watchlist in the jurisdiction(s) in which we operate.
2. Prohibited Uses, Customers and Businesses
  1. Prohibited Uses
Coinhako does not permit users to engage in the following categories of activity. The specific types of use listed below are representative, but not exhaustive:
Fraud, gambling, money laundering, terrorist financing, ransomware, darknet market, scam, hack/stolen funds, blacklisted exchanges, unlicensed money services, abusive, drugs, adult material, weapon (nuclear, biological, and chemical), and activities associated with sanctions.
  1. Prohibited Jurisdictions
Coinhako prohibits establishing business with certain categories of users from, or has exposure to certain jurisdiction(s). This includes but is not limited to jurisdictions with sanctions nexus, severe political instability and/or economical inequality.
  1. Prohibited Customers and Business
Coinhako prohibits conducting business with certain categories of users (individuals, and entities), including but not limited to:
  1. Users known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists;
  2. Users operating in prohibited industries listed in 2(a.) above;
  3. Users in which their identity, or beneficial owners cannot be ascertained;
  4. Users who refuse to furnish information or documents to satisfy our level of due diligence; and
  5. Users in which the legitimacy of its business cannot be ascertained.
Compliance with our AML Program and internal procedures allows us to maintain a 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.