Anti-money laundering and Combating the financing of terrorism Policy (AML/CFT)
Huobi (Thailand) Co., Ltd. (hereinafter “Company”) is well aware that the digital asset business is a new business that is at risk of being the destination of the offender to be used as a place for money laundering and financial support for terrorism. Therefore, Company determines to prevent itself from being as a source of money laundering and counter-terrorism financial support by mean of strictly performing in compliance with the anti-money laundering laws and ranked Anti-money laundering and Combating the financing of terrorism Policy is the principal policy that the Executive Committee, Audit Committee, and all personnel must focus and be involved in considering important issues in all issues including determining any procedures, measures that is a subordinate policies to support the principal policy which are clarified as follows:
According to Article 7 of the Decree on the Digital Asset Assembly 2018, Company as a financial institution under the law on Anti-money laundering. Company is required to have in place a Policy for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) and shall have duties to report transactions to Anti-Money Laundering Office (hereinafter “AMLO”). In order to comply with the intention of the Anti-money laundering laws, Company has therefore provided the Anti-money laundering and Combating the financing of terrorism Policy and several procedures for the Know Your Customer (KYC), Customer Due Diligence (CDD) and Risk management which prevent and alleviate possible risks of Company being an intermediary in money laundering or financing terrorism.
2. Obligation and Responsibility to conduct in accordance with the Policy
2.1 The Board of Directors shall concentrate on and approve Anti-money Laundering and Combating the Financing of Terrorism policy (AML/CFT policy).
2.2 The Board of Executive Directors shall provide the AML/CFT Policy and subordinate policies to comply with the Anti-money Laundering laws as well as provide relevant rules, regulations which are in line with policies on Anti-money Laundering and Combating the Financing of Terrorism, which are in accordance with the policy announced by AMLO.
2.3 The Board of Executive Directors shall supervise that all personnel strictly comply with the policies of Company including relevant laws and regulations.
2.4 The Board of Executive Directors shall adequately support and encourage its personnel to acknowledge and understand on Anti-money Laundering and Combating the Financing of Terrorism in order for them to be able to efficiently comply with anti-money laundering laws.
2.5 All personnel shall have duties to strictly conduct in accordance with the principal and subordinate policies or any measures as published by Company.
3. Know Your Customer /Customer Due Diligence (KYC/CDD)
Know Your Customer and Customer Due Diligence Procedure has in place a procedure on establishing or refusing a relationship with its customers and counterparties by which Company shall obtain their identification information. Company reserves the right to collect all customers’ identification information for its AML/CFT Policy and be able to verify and ensure the identity of the customer as well as to examine against the check-list of exposure persons as specified by laws with the purpose to prevent Company from being involved in any kind of illegal activities.
4. Risk Management
Company has in place a procedure on monitoring the service behavior and any transactions by customer until termination of customer relationship. Company has issued measures for considering the risk which might be related to money laundering and combating financing terrorism which are fit for the customer’s risk level under the anti-money laundering laws and provides proper and adequate measures to examine the facts related to the customer depending on the level of risk arising from the relationship and monitoring the movement of the customer account especially the account of customer who is at risk of money laundering and financing terrorism. In addition, Company has provided the appropriate methods to report any suspicious transaction to AMLO under the terms and conditions of the anti-money laundering laws and relevant regulations.
5. Data storing
6. Employment and training personnel policy
Employment policy is intended to enable the company to have personnel with knowledge, competence and suitable for the position to operate and inspect in accordance with the Company's policy. However, because the company is a new business seeking knowledgeable personnel in all aspects. Whether it is in blockchain technology digital assets include the prevention and suppression of money laundering and financial support for terrorism are difficult. The Company, therefore, has the policy to train personnel to increase knowledge and understanding of the Company's policies. All personnel must have basic knowledge about the transactions that must be reported and how to proceed when finding a suspicious transaction to ensure that all personnel works in line with the Company's policies.
7. Internal audit policy
Company has in place a procedure on supervising the operating system and personnel operations by requiring internal auditors to be independent and impartial without the dominance or intervention from the executive committee and operational personnel, with the form of the audit inspection period, checking method and guidelines for internal auditors to use as a guide in planning the audit.
8. Development and improvement AML/CFT Policy
Company has provided the procedures to develop and improve the AML/CFT policy by AML staff, able to propose modifications to modify the policy under the annual policy update. Policy improvement when finding suspicious transactions and policy updates when new products are available.