Counter Terrorism Financing Policy
AML/CTF Policy Content
WHAT IS AML and CTF?
The phrase “AML” and “CTF” is used regularly in the banking and securities industry. It specifically refers to the AML/CTF Act. In brief, this is the Anti-Money Laundering and Counter-Terrorism Financing Act.
Likewise with banks, Digital Currency Exchange provider are exposed to money laundering. Subsequently trades could be used to launder money and finance terrorism.
What is CTF? It stands for “Countering Terrorism Funding”. Similarly to AML, Digital Currency exchanges can be exposed to Terrorism Funding. Thereby we are required to have controls in place to identify potential Terrorism Funding. AUSTRAC also requires us to report any trade we believe to be suspicious of Terrorism Funding.
All Digital Currency Exchange Providers in Australia are required by Australian law and applicable local laws to abide by certain factors during a trade. Ordinarily they are compliance, risk assessment and training. Additionally, they also include controls and systems in place to mitigate this risk.
AUSTRAC requires all Digital Currency Exchange Providers to do this. However Digital Currency Exchange Providers also do it to protect their reputation and be a good corporate and social citizen.
Both parties involved in FIFObitcoin.com.au have AML and CTF Policies:
McLeod Pacific Investments AML TF Policy
This policy discus’s our legislative obligations as a Digital Currency Exchange Provider.
This applies to all business’s that McLeod Pacific Investments presently own including but not limited to; Fifobitcoin.com.au, Bitcoin_Cam trading handle on Localbitcoins.com, McLeodpacific.com.au and bitcoingoldcoast.com.au.
Money laundering is the action of hiding or disguising the source of illegally procured (“dirty”) funds to make them appear legitimate, e.g. by filtering them into a financial system via banks or other financial institutions.
The object of Money laundering is to reduces the risk of detection by relevant authorities. It is considered just as serious as the criminal activity behind it.
Terrorism financing differs from money laundering in 3 main ways:
- Its single aim is to disguise the ultimate use of the funds, as opposed to their origin
- It often involves relatively small sums of money, which can have a huge impact in terms of potential death, mayhem, destruction, and disruption
- Whilst terrorists may finance their activities through crime, often times legitimate funds can also be misappropriated to support terrorism.
The AML/CTF Act provides a list of ‘designated services’, such as trading Bitcoin for AUD. Before McLeod Pacific performs any of these designated services, traders are required to provide proof of identity and like documentation.
We are required to collect and verify this information, depending on the type of customer:
- Personal – an individual person of any nationality
- A sole trader – a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business
- Domestic company – incorporated in Australia, including proprietary, public and listed public companies
- Foreign company incorporated outside Australia
- Partnership – a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit
- Trust – a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
- Association – a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
- Registered co-operative – a legal entity owned and controlled by the people for whom it was established and who benefit from using its services
- Government body – can be domestic (e.g. Commonwealth, State, Territory) or foreign government body.
Money laundering and terrorism financing (ML/TF) are often identified because a trader behaves in a suspicious manner.
For a ‘suspicious manner’ to be validated, we must have reasonable grounds to believe ML/TF activity may be occurring. To validate suspicion our owners and employees receive training in identifying and reporting suspicious matters.
McLeod Pacific Investments 4 key AML/CTF principles
- Comply with AML/CTF legislation in Australia.
- Work with the Australian Government and its agencies to reinforce their objectives in relation to the prevention, detection and control of ML/TF
- We may decide not to provide Bitcoin and crypto trading services dependent on decisions guided by ML/TF risk appetite and good corporate and social responsibility
- We manage an AML/CTF program, to a standard as required by Australian AML/CTF legislation and AUSTRAC.
Our Policy Roles and Responsibilities
McLeod Pacific Directors and Senior management are responsible for ongoing oversight and review of our AML/CTF policy and procedures. Any McLeod Pacific Investments employees are required to adhere to these, be trained in these matters and report suspicious matters if and when they occur.
As per AUSTRAC requirements McLeod Pacific Investments Pty Ltd have a dedicated AML/CTF Officer Their responsibility is to monitor status and effectiveness of the our AML/CTF risk management and compliance.
Our AML/CTF Program (in summary)
Our AML/CTF Program was designed to factor in what we determine to be in line with our risk profile as a Digital Currency Exchange Provider. These include:
- ML/CF risk assessment
- Owner and Employee due diligence
- Owner and Employee Training
- Monitoring of Transactions and Reporting
Further AUSTRAC Obligations
As an AUSTRAC registered Digital Currency Exchange Provider, we are also required to report the following to AUSTRAC:
- Electronic Transfer of Funds or Bitcoin into and out of Australia
- Any Trade that we would deem as suspicious
- Any cash trade that is equal to or exceeds $10000.