Know your Transaction Policy
for CoinsAu

CoinsAU (the “Company”) is committed to ensuring compliance with regulatory requirements and maintaining a secure cryptocurrency trading environment through a robust Know Your Transaction (KYT) Policy. The following outlines the procedures and practices the company shall adhere to in preventing illicit activities, enhancing due diligence, and complying with applicable laws and regulations in Australia.

Client Onboarding

The Company commits to the following procedures during the client onboarding process:

• Conduct thorough customer due diligence (CDD).
• Verify customer identity using reliable sources, adhering to Anti-Money Laundering (AML) regulations.
• Collect comprehensive information, including proof of identity, residential address, and source of funds.

Wallet Monitoring

The company shall implement the following measures for continuous wallet monitoring:

• Continuously monitor client wallets to detect unusual or suspicious activity.
• Utilize automated tools to track transactions, with a focus on large or rapid fund movements.
• Regularly update and review wallet information to ensure accuracy and relevance.

The Company is committed to AML compliance through the following actions:

Chainalysis Technology Integration:

To enhance blockchain analytics, the company shall:

• Integrate Chainalysis or similar technology solutions.
• Utilize Chainalysis tools to trace the source and destination of funds, identifying high-risk transactions.
• Stay informed about emerging threats and vulnerabilities in the cryptocurrency space through continuous training and updates on Chainalysis features.

Reporting and Compliance

The Company commits to maintaining compliance and timely reporting:

• Maintain accurate records of customer transactions and KYC information.
• Report suspicious transactions promptly to the relevant authorities.
• Collaborate with law enforcement and regulatory bodies, providing necessary information for investigations.

7. Training and Awareness

The company shall focus on training and fostering a culture of compliance:

• Regularly train employees on the latest AML and KYC procedures.
• Foster a culture of compliance, emphasizing the importance of diligence in combating financial crimes.
• Stay informed about industry best practices and regulatory updates to adapt policies accordingly.

8. Regular Audits

Internal audits shall be conducted periodically:

• Assess the effectiveness of KYT procedures through periodic internal audits.
• Engage third-party auditors to ensure an unbiased evaluation of compliance.
• Adjust policies based on audit findings to enhance the effectiveness of the KYT framework.

9. Illicit and Legitimate Services

Monitoring shall extend to both illicit and legitimate services:

• Implement comprehensive monitoring for illicit services, including darknet markets, scams, and ransomware.
• Scrutinize legitimate services such as merchant services, decentralized cryptocurrency exchanges, NFT platforms, and bridges.
• Regularly update the monitoring system to adapt to evolving trends in both illicit and legitimate crypto activities.

10. Cryptocurrency Asset Monitoring

The company shall extend KYT to monitor transactions involving all cryptocurrency assets:

• Ensure a holistic approach to transaction surveillance.
• Detect patterns of high-risk activity and prevent transactions involving addresses listed on OFAC’s sanction list.

11. Real-time Alerts and Compliance

• Configure real-time alerts based on the organization's AML compliance policies.
• Ensure that the monitoring system provides alerts for transactions involving sanctioned addresses and potential threats.
• Regularly review and update alert configurations based on emerging risks and regulatory changes.

12. Entity Address Monitoring

Monitoring shall cover all addresses controlled by an entity:

• Gather real-time intelligence on the source or destination of funds.
• Leverage KYT for vetting users within the platform, enhancing overall security and compliance measures.

13. Flexibility and Adaptability

The Company shall maintain flexibility in its KYT system:

• Adapt to the dynamic nature of the cryptocurrency landscape.
• Regularly review and update the KYT policy to incorporate emerging technologies and industry best practices.
• Collaborate with industry experts to stay informed about the latest advancements in transaction monitoring and blockchain analytics.

14. Data Protection and Privacy

The Company acknowledges the importance of protecting customer data and privacy:

• Implement robust measures to safeguard customer information, ensuring compliance with data protection laws.
• Regularly conduct privacy impact assessments to identify and address potential risks to customer data.
• Provide transparent communication to customers regarding data collection, storage, and usage.

15. Customer Communication and Education

The company shall focus on effective communication and customer education:

• Maintain clear and transparent communication channels with customers.
• Educate customers about the importance of KYT measures and how they contribute to a secure cryptocurrency environment.
• Provide regular updates on security best practices and emerging threats to enhance customer awareness.

16. Incident Response and Reporting

In the event of a security incident, the Company commits to:

• Establish a robust incident response plan to address and mitigate the impact of security breaches promptly.
• Report security incidents promptly to regulatory authorities and affected customers in accordance with legal requirements.
• Conduct thorough post-incident reviews to identify areas for improvement in the incident response plan.

17. Vendor Management

When engaging third-party vendors, the company shall:

• Conduct due diligence on vendors to ensure they comply with AML and KYT standards.
• Establish clear contractual obligations regarding data protection, security, and adherence to regulatory requirements.
• Periodically assess the performance and compliance of vendors to mitigate risks associated with external partnerships.

18. Continuous Policy Review and Updates

The Company recognizes the dynamic nature of the cryptocurrency industry and commits to:

• Conduct regular reviews of the KYT policy to align with emerging regulatory requirements and industry best practices.
• Implement updates promptly to address evolving risks, technological advancements, and changes in the regulatory landscape.
• Communicate policy updates internally and to customers in a transparent manner.

19. Board and Senior Management Oversight

The company's Board and Senior Management shall:

• Provide oversight and review of the effectiveness of the KYT policy.
• Ensure that adequate resources are allocated for the implementation and maintenance of KYT measures.
• Receive regular reports on KYT compliance and effectiveness.

20. Adopting and amending this Policy

This Policy may be amended at any time. Any change to this Policy must be approved and adopted formally by the Director(s)/Senior Management.