Anti-money laundering policy and against financial support for terrorism
Huobi (Thailand) Co., Ltd. (“Company”) registered in the form of a limited company under the civil and commercial code with the company partnership registration office, Department of Business Development, Ministry of Commerce. The company has applied for a license to operate a digital asset trading center with the Securities and Exchange Commission. To provide trading services to exchange digital assets to the general public in general and provide services as a central market to exchange digital assets of customers who own or operate digital assets.
According to Article 7 of the Decree on the Digital Asset Assembly 2018 providing the digital asset trading center to be a financial institution under the law on prevention and suppression of money laundering. The company is therefore considered to have a duty to report transactions and must establish a policy to prevent and suppress money laundering and counter-terrorism financial support
The 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. To allow Thailand to be recognized internationally on anti-money laundering standards. The company has therefore ranked the policy to prevent and suppress money laundering and against financial support for terrorism is the main policy that the Executive Committee, Audit Committee, and all personnel must focus and be involved in considering important issues in all issues
Executive Committee, Audit Committee, Manager, staff AML and all personnel in the company must cooperate, support and work in accordance with the main policy and secondary policy as determined by the company
The company has provided a policy to accept customers as a secondary policy which is part of the main policy. Which can be divided into 3 sub-policies, namely the policy of providing customers with identity. Policy for checking information and identification documents and approval policies for customers by requiring customers to fill out and submit documents to be higher than the standards announced by the Prime Minister's Office. Subject to the method of identification of customers, financial institutions and professionals under article 16 (2001) announcement. In addition, there is a need to have an inspection process to know the facts about customers intensely. That is, there is a personal history check according to the civil registration, history of money laundering and the risk of money laundering, financial support for terrorism and customer bankruptcy history to consider and approve the company's customers
When the company approves the customer to use the service. The company has established a policy to manage money laundering risks and financial support for terrorism as a secondary policy that is part of the main policy. In order to monitor customer service behavior and always review customer risks and checking transactions with reasonable suspicions and having to report to the Office of the Anti-Money Laundering Committee. Which can be divided into 2 sub-policies, namely customer risk assessment policy, and policy to prevent or reduce risks.
The customer risk assessment policy requires the company to transforming customer data into a risk rating factor which the risk factor consists of product form customer type, customer careers, purpose of applying for services, source of income, the amount of cash or digital assets that are expected to be invested and history of cases relating to property and bankruptcy. The company has assigned the authority of AML employees to rate additional risks to increase the risk level of customers. There will be a collection of risk points for each customer and divide the risk level of customers into 4 levels, including low-risk customers, medium-risk customers, high-risk customers, and customers with high risks as required by law.
Once the customer risk level has been determined the policy to prevent or reduce risks is divided into 2 policies. It is the policy that applies to the first service and policies that apply to the second type of service.
The policy that applies to the first type of service also called “Sieve 5 layers” to screen all customers, leaving only customers with standards and quality under the law on prevention and suppression of money laundering.
1. Sieve 1 consists of a system to compare customer data by comparing the information that customers fill in and deliver documents and actual service behavior when customers use the service for one month and the first quarter, then use the service behavior to evaluate and adjust the risk level. This is because the company may not trust the information and documents that the customers have sent to the company. Therefore, need to check the actual usage behavior of the service together to provide the most accurate and accurate level of customer risk which will affect the checking of customers according to the level of risk.
2. Sieve 2 is an examination of the service of depositing, withdrawing cash or digital assets by forcing customers to deposit, withdraw cash or digital assets through a bank account or wallet number of the customers that are notified to the system only in order to prevent deposits and withdrawals. In addition, there is a limit on the amount of withdrawals to reduce damage from money laundering and financial support to terrorism and forcing customers to clarify the transaction and request approval for withdrawal in the event that customers withdraw cash or digital assets in excess of the limit as required by law.
3. Sieve 3: It is an examination of the overall picture of the use of services for all customers whether there is an abnormal trading behavior or not which includes checking the price, jumping or chasing price and the use of spaces between the bid price and the offering price.
4: Is an examination of the behavior of individual customers whether there is an abnormality or not. The system will detect when a customer has a behavior that has a suspicious reason consists of a credit check system, avoiding clarification of transactions and requesting approval for withdrawal, abnormal withdrawal behavior, and financial advisors
Sieve 5 is the final inspection, therefore, requires intensive examination according to the risk level of the customer that is customers with a higher risk level should have an intensive examination and a shorter inspection period than customers with lower risk. Whether it is forcing customers to fill out and submit new documents, the system to check the profit and loss from trading in digital assets, behavior detection system to avoid detection and the comparison system of service behavior. There are also training seminars to invite customers to exchange knowledge.
The policy that applies to the second type of service is to monitor customers who own or operate digital assets. This is to prevent or reduce the risk of money laundering and anti-terrorism financing at the source. That is, customers who own or operate digital assets are considered the starting point of forex trading. If customers, who own or operate digital assets, produce, sell and control their digital assets to have standards of prevention and suppression of money laundering and anti-financial support for quality terrorism will reduce risks and help prevent and suppress money laundering when customers trade and exchange digital assets. Therefore, the examination consists of checking whether the customer has implemented the policy as explained or not. Digital asset social network monitoring, the company will cooperate with customers to market to detect irregularities and contract service agreements made in year-to-year only.
In addition, the company has established a policy to maintain customer data in accordance with anti-money laundering laws. By storing all customer data for at least 10 years from the date of the transaction and must be maintained for 5 years from the date that the relationship with the customer is terminated.
The company recognizes that personnel is an important part of the implementation of the company's policies. The company, therefore, has the policy to hire and train personnel as a secondary policy which is part of the main policy. Which can be divided into 2 sub-policies. That is the employment policy and personnel training policy. The 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 policy.
In addition, the company is well aware that the operating system and personnel operations are in accordance with the company's policy. There may be fraud or errors. The company, therefore, has established an internal audit policy as a secondary policy which is part of the main policy. 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.
Finally, the company is well aware that the policies established by the company are all the basic structures that must be improved in accordance with the behavior of customers in the future. The company, therefore, has the policy to develop and improve the 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.
The company aims to have growth in economic terms consistent with the development of sustainable social quality (good governance). Prevention and suppression of money laundering and financial support for terrorism is an important part that will help develop society and Thailand to be stable and sustainable. The company has a strong commitment to all personnel to comply with the policy and improve the policy to be effective and efficient to prevent customers from using the company as a place for money laundering and financial support for terrorism.