AML Policy

1. Introduction


Vortex Digital (the "Fintech") is committed to preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines the measures and procedures implemented to ensure compliance with applicable AML laws and regulations.


2. Definitions


Money Laundering: The process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.

Terrorist Financing: The provision of funds for terrorist activities.

Customer Due Diligence (CDD): The process of verifying the identity of customers and assessing the risks they pose.

Suspicious Activity Report (SAR): A report filed by financial institutions about suspicious or potentially suspicious activity.


3. Objectives


The objectives of this AML Policy are to:

Comply with all relevant AML regulations and guidelines.

Detect, prevent, and report potential money laundering and terrorist financing activities.

Ensure that all employees are aware of their responsibilities in the fight against money laundering and terrorist financing.


4. Responsibilities


Board of Directors: The Board is responsible for overseeing the implementation and effectiveness of the AML Policy.

Compliance Officer: The Compliance Officer is responsible for the day-to-day management of AML activities, including reporting and training.

Employees: All employees must comply with the AML Policy and report any suspicious activities to the Compliance Officer.


5. Customer Due Diligence (CDD)


Identification and Verification: The Fintech will verify the identity of all customers before establishing a business relationship. This includes obtaining and verifying information such as name, date of birth, address, and identification number.

Risk Assessment: Customers will be assessed for their risk of money laundering and terrorist financing. High-risk customers will be subject to enhanced due diligence (EDD).

Ongoing Monitoring: The Fintech will continuously monitor transactions and customer behavior to identify and report suspicious activities.


6. Enhanced Due Diligence (EDD)


For customers identified as high risk, the Fintech will apply additional measures, including but not limited to:

Obtaining additional information on the customer and their intended transactions.

Conducting more frequent and thorough reviews of the customer's account activity.

Requiring senior management approval for establishing or continuing business relationships with high-risk customers.


7. Record Keeping


The Fintech will maintain records of all CDD information, transaction data, and SARs for at least five years.

Records will be stored securely and be readily available for inspection by regulatory authorities.


8. Reporting Suspicious Activity


Employees must report any suspicious activity to the Compliance Officer immediately.

The Compliance Officer will review all reports and, if necessary, file a SAR with the appropriate authorities.


9. Training


All employees will receive AML training upon joining the Fintech and regularly thereafter.

Training will cover relevant AML laws and regulations, identification and reporting of suspicious activities, and the Fintech's AML procedures.


10. Audit and Review


The AML Policy will be reviewed annually by the Compliance Officer to ensure its effectiveness.

Regular independent audits will be conducted to assess compliance with the AML Policy and identify areas for improvement.


11. Sanctions


Non-compliance with the AML Policy by employees may result in disciplinary action, including termination of employment.

The Fintech may terminate relationships with customers found to be engaged in money laundering or terrorist financing.


12. Confidentiality


All reports and records related to suspicious activity and AML compliance will be treated as confidential and only shared with relevant authorities and personnel as required by law.


13. Governing Law


This AML Policy is governed by the laws of the United Kingdom and complies with the requirements of the Financial Conduct Authority (FCA) and other relevant regulatory bodies.


14. Contact Information

For any questions or concerns, Users can contact the Bank through the following means:


Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.


By using the Fintech's services, Users acknowledge that they have read, understood, and agreed to these terms and conditions.

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