Last updated 20th of November 2023
To ensure strict adherence to international trade standards, we operate in full compliance with regulations aimed at combating money laundering and countering the financing of terrorism. To monitor our compliance with legal requirements and the recommendations of FATF (Financial Action Task Force), we have established a dedicated Compliance department responsible for developing Anti-money laundering and Know Your Customer (AML/KYC) procedures. These procedures are mandatory for all employees and customers, guiding our interactions with anyone seeking to become our customer. The Compliance Department plays a crucial role in ensuring that all NORDEK operations align with international anti-money laundering standards and that customer-provided documents are current and in accordance with applicable legal regulations.
The purpose of this Anti-Money Laundering (AML) Policy is to outline NORDEK's commitment to preventing money laundering, terrorist financing, and other illicit financial activities on our platform. This policy serves as a foundation for our AML efforts and is an integral part of our compliance framework.
As our client, you must fully commit to and abide by the following AML and KYC rules:
• You are obligated to adhere to our AML and KYC requirements throughout your client relationship. The NORDEK may request additional documents and information from you, and completing the respective KYC questionnaire may be mandatory based on the NORDEK’s discretion. You agree to these requirements and commit to their compliance.
• We undertake measures to verify the identity of the user in the process of proving whether a person actually is who they claim to be. This is done by carrying out checks to verify the correctness of the document provided by the client.
• If you fail to provide the requisite KYC documents asked by NORDEK or any additional information or documents related to identification, then NORDEK reserves the right to that it may temporarily hinder or completely restrict your use of the platform.
• Asset withdrawals can only be made to your own account; transferring assets to third parties is strictly prohibited. Internal transfers between the NORDEK’s customers are also not allowed.
• You agree to undertake that you shall not misrepresent or impersonate other persons or use the platform for any activity which is not legal under any circumstances.
• The NORDEK is obligated and authorized, without prior consent, to share any necessary details that you understand and agree that, in case of AML related sanctions suspected or present on your wallet. NORDEK reserves the right to return deposits made from such wallets and or disallow withdrawal / further transfer of VDAs to any other wallet. The information about you with financial institutions and law enforcement agencies should be in accordance with applicable laws. You grant your consent for these actions, and the NORDEK maintains transaction records for at least the last five years to comply with this requirement.
• You pledge to follow the laws, including international regulations, aimed at combatting illegal trafficking, financial fraud, money laundering, and the legitimization of unlawfully acquired funds. You must make every effort to avoid any involvement in illegal financial activities or transactions through the NORDEK’s Website and Services.
• You agree and undertake to ensure that the funds transferred by you to your account with NORDEK are from your own bank account or from exchange wallets/un-hosted wallets which are held in your name and are in your control, and have been derived through legitimate means in compliance with Applicable Laws.
• You guarantee the legal origin, ownership, and right to use the assets transferred to your account. In cases of suspicious transactions, deposits from untrusted sources, or any actions resembling fraud, the NORDEK reserves the right to conduct an internal investigation, block or close your Traders Room or any account, cancel payments or trading orders, and suspend account operations pending an official investigation. The NORDEK’s decisions are guided by applicable laws, FATF recommendations, or common industry practices.
• The NORDEK may request additional information if the withdrawal method differs from the depositing method, and it reserves the right to block your Traders Room or any account during an investigation if you refuse to provide the requested additional information.
• During an investigation, the NORDEK may request additional copies of documents confirming identity, as well as documents confirming residency and the legal origin of funds. In case of doubt, the NORDEK may demand the provision of original documents for review.
• The NORDEK does not offer services to individuals and entities located in jurisdictions “blacklisted” by FATF.
• The NORDEK may refuse to carry out operations it deems suspicious, and the use of preventive measures (e.g., blocking or closing an account) does not make the NORDEK liable for failing to fulfil its obligations to you.
• The NORDEK is not obligated to inform you or other parties about the measures taken to comply with AML/CFT legislation or about any suspicions, reasons for refusal to execute your orders, account opening denials, or document requests, among other actions.
• This document serves as a summary of our commitment to contributing to the global AML initiative, but each NORDEK may have its own internal AML and KYC procedures and rules that complement the rules outlined in this summary. This summary should not be viewed as an unchangeable rule and may be supplemented by a specific NORDEK’s local AML policy.
• This anti-money laundering and know your customer policy is an integral part of any agreement between you and the NORDEK. Non-compliance with this policy may lead to the agreement’s termination at the NORDEK’s discretion.
In light of the adverse impacts of money laundering, such as undermining digital asset trading development, fostering corruption, compromising social ethics, and harming the legitimate rights of users, as well as the need to maintain the integrity of digital asset trading platforms, this website has established these rules in alignment with the Website User Agreement. The primary objective is to prevent money laundering, terrorist financing, and ensure full compliance with anti-money laundering and anti-terrorist financing regulations. Given website global clientele, it may encounter inquiries from law enforcement agencies worldwide. As a result, this website is committed to adhering to the various legal requirements imposed by local authorities. These rules delineate the procedures for averting money laundering, terrorist financing, and corruption. Website goal is not merely regulatory compliance, but also the effective mitigation of risks associated with criminal exploitation. Hence, the anti-money laundering, terrorist financing, and corruption policies are founded on the highest requisite standards.
These Rules are applicable to all users engaging in trading activities on this website and its associated app, collectively referred to as ‘the Platform.’ Users are required to adhere to these Rules in compliance with the anti-money laundering and anti-terrorist financing laws and regulations of their respective countries or regions, within the boundaries set by the local laws and regulations. We can restrict the usage of the platform for a user if they fail to comply with the requirements mentioned in this policy.The rules are made and governed and interpreted in accordance with the laws of local authorities but if a country requires a separate order of jurisdiction or stricter requirements then the jurisdiction of that country prevails. The jurisdiction is de decided from the country of the user.
This term encompasses actions for which measures have been established in accordance with relevant laws, rules, and regulations. The purpose is to prevent individuals from using the Platform to launder the proceeds and profits derived from unlawful activities such as drug-related crimes, organized crime, terrorism, smuggling, corruption, bribery, financial fraud, breaches of financial regulations, and other related offenses while attempting to conceal the source and nature of these funds.”
The Platform evaluates user risks based on the following principles:
• Comprehensive Approach: The Platform considers various risk factors that may indicate money laundering and monitors all users accordingly.
• Prudent Monitoring: By thoroughly understanding users, the Platform enhances identity verification and exercises caution in risk monitoring.
• Sustainable Response: The Platform pays attention to user risks and responds to them based on each risk’s specific circumstances.
• Confidentiality: User identity, transaction, and risk information held by the Platform is kept strictly confidential and only disclosed as required by law or regulatory authorities.
• Hierarchical Management: The Platform periodically reviews user information according to their risk levels, with more stringent reviews for higher-risk users.
The Platform conducts its anti-money laundering efforts through money laundering affairs guidance group and a dedicated team for advancing anti-money laundering activities. These teams include members from the Platform’s risk control and compliance departments.
The money laundering affairs guidance group is tasked with planning, directing, and coordinating the Platform’s efforts in combatting money laundering. Its specific duties include:
• Reviewing and approving the Platform’s money laundering policies, work plans, and reports.
• Establishing and updating the guiding principles and anti-money laundering rules for the Platform.
• Evaluating the organizational structure and responsibilities related to money laundering for both the Platform and its sub-websites.
• Developing and implementing internal transaction inspection and control procedures.
• Addressing significant and complex issues pertaining to money laundering and devising solutions.
The composition of the team responsible for advancing the fight against money laundering is determined based on regulatory requirements and location-specific factors. Its primary functions encompass:
• Executing the anti-money laundering rules and directives set by the money laundering affairs guidance group.
• Carrying out various assignments.
• Analysing and identifying the identity and background of users involved in suspicious transactions, as well as the suspicious transactions themselves.
• Assessing and adjusting the risk level of users.
• Conducting continuous due diligence and monitoring of users.
• Periodically reviewing completed transactions.
• Reporting any suspicious transactions to competent authorities.
• Assisting in investigations when requested by competent authorities.
Upholding principles of diligence and understanding the user base, the Platform conducts due diligence on all users. For high-risk users, the Platform reserves the right to conduct enhanced due diligence.
Due diligence is carried out at different stages. Some of them are listed below -
• when a user registers
• when a user account is reviewed regularly
• when a user executes a transaction on the Platform
• when the Platform questions the accuracy, legitimacy, or sufficiency of previously obtained user identification data.
This is not at an exhaustive list i.e. the process of diligence shall include but may not be only limited to these steps.
The Platform is authorized to investigate the following types of suspicious transactions and accounts:
• Swift and unusual transfers of digital assets, either in or out, over a short timeframe, which do not align with the user’s known identity, financial activity, or business operations.
• The abrupt reactivation of long-inactive accounts or a sudden influx of digital assets into an account that typically sees minimal activity, followed by a substantial withdrawal of funds within a brief period.
• The excessive opening or closure of accounts without valid justification, combined with substantial currency deposits or withdrawals prior to such account closures.
• Suspicious large-sum deposits or withdrawals in the account of an individual user.
• Instances where a user engages in abnormally frequent trading within a specific time frame, greatly deviating from the typical digital asset market conditions.
• Any other unusual trading situations identified by the Platform as suspicious.
Any Platform staff member who encounters information pertaining to anti-money laundering in the course of their duties shall adhere to strict confidentiality requirements. They must keep all user identity information, details of suspicious transactions, terrorist financing activities, and any related data strictly confidential. Such staff members are prohibited from sharing this information with any external organization, individual, or other Platform staff members not directly involved.
We undertake adequate screening procedures while hiring staff and train them on AML & CFT policies, new AML & CFT laws and regulations including on client on boarding, KYC, client due diligence, sanctions screening, customer identification, record-keeping and transaction processing and review.
NORDEK designates an AML Compliance Officer responsible for overseeing and enforcing the AML policy, conducting risk assessments, and ensuring that AML procedures are followed.
This AML policy is communicated to all employees, stakeholders, and relevant third parties to ensure adherence and compliance. Failure to adhere to this policy may result in legal and disciplinary actions.
Employees and stakeholders are encouraged to report any suspected violations of this policy to the AML Compliance Officer.
This AML policy is subject to periodic review and updates to remain in compliance with changing regulations and emerging AML risks.
NORDEK is committed to maintaining a strong AML program to prevent money laundering and illicit financial activities within our ecosystem. We recognize our responsibility to society and the global financial system in fighting against financial crimes.