Política AML

Anti-Money Laundering and Combating Financing of

Terrorism (CFT) Policy

Introduction

PopeyeX Blockchain Ecosystem Global Inc (PopeyeX) a company incorporated in Panama is a

Virtual Digital Assets Service Provider which provides a trading platform for clients to buy and

sell virtual digital assets, send and receive virtual digital assets and also a platform for storing

their VDA.

As an organization, PopeyeX is subject and committed to the observance of the Anti-Money

Laundering (AML) legislative and regulatory regimes applicable in Panama.Legislation :-

Panama’s main money laundering laws are:

a) Law 23 of 2015 – this is aimed at preventing money laundering and the proliferation of

weapons of mass destruction

b) Law 11 of 2015 – this deals with international judicial assistance in criminal cases

c) Law 21 of 2017 – this adopted rules to regulate trusts under the supervision of the

banking sector regulatory

d) Law 70 of 2017 – this criminalized tax evasion as a predicate crime

e) Law 129 of 2020 – this approved the creation of a beneficial ownership registry

f) Law 81 of 2019 - this governs personal data protection

This document covers the systems and procedures adopted by PopeyeX to ensure

compliance with the prevalent AML regulations.

What is Money Laundering?

As per Law 23 of 2015, Money Laundering includes the following:-

● Transferring or moving proceeds or conducting any transaction with the aim of

concealing or disguising their illegal source;

● Concealing or disguising the true nature, source, or location of the proceeds as well as

the method involving their disposition, movement, ownership of or rights with respect

to said proceeds;

● Acquiring, possessing, or using proceeds upon receipt;

● Assisting the perpetrator of the predicate offense to escape punishment.Implementation at PopeyeX

At PopeyeX, we have implemented appropriate Anti-Money Laundering (AML) - Counter

Financing of Terrorism (CFT) practices across our business in accordance with local AML

legislations and best industry standards. We adopt the use of AML-compliant software that is

meticulously tailored to meet Know Your Customer (KYC) and Customer Due Diligence (CDD)

requirements within the digital assets' ecosystem. Our approach focuses on adopting a

combination of measures under our AML Compliance Program to prevent our business from

being used to introduce proceeds of crime into the financial system or as a means to

perpetrate financial crime.

Anti-Money Laundering Compliance Policy Declarations

● PopeyeX is fully committed to observing internationally accepted principles of AML-CFT

compliance and adhering to local and international AML laws and regulations. We

commit to observing and reflecting within our processes the relevant

recommendations issued by bodies such as the Financial Action Task Force (FATF) on

preventing the utilization of our operations for criminal purposes.

● Accordingly, we take necessary procedures and control measures to provide the

optimum support in the fight against money laundering and financing of terrorism.

● Furthermore, PopeyeX is committed to continually fulfilling its Anti-Money Laundering

(AML) obligations to its local and foreign associates and correspondent banks/

vendors that may sometimes require due diligence information on accounts and

transactions.

● PopeyeX will fulfill any such obligations in accordance with applicable legislation or

regulations to which it is subject and under the guidelines and recommendations of

the FATF.

● PopeyeX pledges to examine, review, and update its AML processes and control on an

ongoing basis and maintain high standards of processes through reporting and audit

examinations and random testing of our AML Compliance Program.

Appointment of a Money Laundering Reporting Officer

PopeyeX appoints at all times within its employment a Money Laundering Reporting Officer

(MLRO) with full responsibility for establishing and maintaining our AML Compliance Program.

The MLRO is responsible for implementing PopeyeX' AML Compliance Program; effectively

monitoring compliance with applicable AML legislations and regulations; overseeing the

day-to-day operation of AML systems and controls, establishing and implementing an

appropriate training program for PopeyeX' employees; receiving and investigating internalsuspicious transaction reports and where appropriate, submitting external suspicious

transaction reports to the relevant authorities.

Customer Identity Verification

Prior to opening an account on PopeyeX and assessing the PopeyeX platform, PopeyeX will

mandatorily verify each customer's identity and screen each customer against local and

international blacklists and sanctions lists, PEP lists and adverse media. PopeyeX meticulously

adheres to its Know Your Customer/Customer Due Diligence procedures and guidelines. This

involves all necessary actions to ensure that its customers are real persons and that the risks

of money laundering, financing of terrorism and other financial crimes are properly identified

and mitigated.

PopeyeX undertakes due diligence of its customers prior to account opening and on an

ongoing basis throughout the business relationship. PopeyeX may refuse to open an account

or halt a customer's continued access to the PopeyeX platform if the customer does not meet

our initial or ongoing KYC requirements.

Establishment of Beneficial Ownership of Funds

PopeyeX is required under applicable legislation and/or regulation to identify the beneficial

owner of all transactions undertaken on the PopeyeX platform and/or funds held in a PopeyeX

account. No customer is permitted to act on behalf of a third party while transacting on

PopeyeX. PopeyeX considers all persons holding an account or transacting through PopeyeX to

be the beneficial owner of the funds held in a PopeyeX account or transaction executed

through PopeyeX. PopeyeX may halt a customer's continued access to the PopeyeX' platform if

the customer is found to be acting on behalf of third parties.

Enhanced Know Your Customer/Due Diligence

Enhanced due diligence is conducted when a customer is deemed as exposing PopeyeX to a

high AML risk and/or when a transaction appears to be potentially suspicious based on

well-defined red flag indicators. Our client relationship staff will request additional KYC

documents such as proof of source of the fund or additional identification documents as

may be necessary to appropriately mitigate the risk. In such cases, in-depth due diligence is

conducted outlining the expected and actual transaction behavior and the ongoing

monitoring of transactions that may reveal potentially suspicious activities. Senior

management approval is required prior to approving customers with high AML risk exposure.On-going Transaction Monitoring

On an ongoing basis, our platform enables us to analyze the transaction behavior of the

users while monitoring the volumes and frequency of their transactions. In addition to the

above, our tools enable us to identify the red flags based on different parameters we use for

risk profiling of our customer base such as:

● Occupation/profession

● Expected transaction volumes and frequency

● Age

● Nationality

● Location

● Source of FIAT currency

● Source and Destination of VDA

Customers deemed as having high AML risk exposure are subject to more stringent and

frequent ongoing transaction monitoring. PopeyeX maintains the use of systems to effectively

monitor its customers and all transactions executed through the PopeyeX platform. Suspicious

transactions or activity on PopeyeX are subject to investigation.

Internal Reporting of Unusual/Potentially Suspicious Transactions

All client relationship staff liaising with the client(s) for increased limits requests and

overseeing subsequent remittances in the client's account are required to report any

potentially/actual suspicious or unusual transactions to the MLRO using our internal reporting

system.

Reporting of Unusual/Suspicious Transactions/Activity

All PopeyeX staff are required to monitor, detect and report unusual/potentially suspicious

activities or transactions to the MLRO, who will in turn, conduct an in-depth investigation, and

determine whether an external report should be made to the relevant authorities.

Record Keeping

PopeyeX maintains a record of all information and documentation obtained from its

customers during the customer onboarding process and thereafter throughout the duration

of the relationship between PopeyeX and the customer. Records maintained by PopeyeX

include customers' identification documents, transaction data, and any other related

documents. Records are retained as long as the customer holds an account with PopeyeX andsubsequently for a minimum period of eight years after the closure/redundancy of the

account, in accordance with Law 23 of 2015 and other relevant regulations.

Confidentiality of Records and Suspicious Transactions

All customer records and transactional information are kept confidential and in compliance

with Law 81 of 2019 on Panama Personal Data Protection at all times, and the customers are

not intimated if their transactions are considered suspicious and being reported to the MLRO

internally or are being filed as with regulatory authorities.

For any queries the MLRO can be contacted at [email protected]

Anti-Money Laundering and Combating Financing of

Terrorism (CFT) Policy

Introduction

PopeyeX Blockchain Ecosystem Global Inc (PopeyeX) a company incorporated in Panama is a

Virtual Digital Assets Service Provider which provides a trading platform for clients to buy and

sell virtual digital assets, send and receive virtual digital assets and also a platform for storing

their VDA.

As an organization, PopeyeX is subject and committed to the observance of the Anti-Money

Laundering (AML) legislative and regulatory regimes applicable in Panama.Legislation :-

Panama’s main money laundering laws are:

a) Law 23 of 2015 – this is aimed at preventing money laundering and the proliferation of

weapons of mass destruction

b) Law 11 of 2015 – this deals with international judicial assistance in criminal cases

c) Law 21 of 2017 – this adopted rules to regulate trusts under the supervision of the

banking sector regulatory

d) Law 70 of 2017 – this criminalized tax evasion as a predicate crime

e) Law 129 of 2020 – this approved the creation of a beneficial ownership registry

f) Law 81 of 2019 - this governs personal data protection

This document covers the systems and procedures adopted by PopeyeX to ensure

compliance with the prevalent AML regulations.

What is Money Laundering?

As per Law 23 of 2015, Money Laundering includes the following:-

● Transferring or moving proceeds or conducting any transaction with the aim of

concealing or disguising their illegal source;

● Concealing or disguising the true nature, source, or location of the proceeds as well as

the method involving their disposition, movement, ownership of or rights with respect

to said proceeds;

● Acquiring, possessing, or using proceeds upon receipt;

● Assisting the perpetrator of the predicate offense to escape punishment.Implementation at PopeyeX

At PopeyeX, we have implemented appropriate Anti-Money Laundering (AML) - Counter

Financing of Terrorism (CFT) practices across our business in accordance with local AML

legislations and best industry standards. We adopt the use of AML-compliant software that is

meticulously tailored to meet Know Your Customer (KYC) and Customer Due Diligence (CDD)

requirements within the digital assets' ecosystem. Our approach focuses on adopting a

combination of measures under our AML Compliance Program to prevent our business from

being used to introduce proceeds of crime into the financial system or as a means to

perpetrate financial crime.

Anti-Money Laundering Compliance Policy Declarations

● PopeyeX is fully committed to observing internationally accepted principles of AML-CFT

compliance and adhering to local and international AML laws and regulations. We

commit to observing and reflecting within our processes the relevant

recommendations issued by bodies such as the Financial Action Task Force (FATF) on

preventing the utilization of our operations for criminal purposes.

● Accordingly, we take necessary procedures and control measures to provide the

optimum support in the fight against money laundering and financing of terrorism.

● Furthermore, PopeyeX is committed to continually fulfilling its Anti-Money Laundering

(AML) obligations to its local and foreign associates and correspondent banks/

vendors that may sometimes require due diligence information on accounts and

transactions.

● PopeyeX will fulfill any such obligations in accordance with applicable legislation or

regulations to which it is subject and under the guidelines and recommendations of

the FATF.

● PopeyeX pledges to examine, review, and update its AML processes and control on an

ongoing basis and maintain high standards of processes through reporting and audit

examinations and random testing of our AML Compliance Program.

Appointment of a Money Laundering Reporting Officer

PopeyeX appoints at all times within its employment a Money Laundering Reporting Officer

(MLRO) with full responsibility for establishing and maintaining our AML Compliance Program.

The MLRO is responsible for implementing PopeyeX' AML Compliance Program; effectively

monitoring compliance with applicable AML legislations and regulations; overseeing the

day-to-day operation of AML systems and controls, establishing and implementing an

appropriate training program for PopeyeX' employees; receiving and investigating internalsuspicious transaction reports and where appropriate, submitting external suspicious

transaction reports to the relevant authorities.

Customer Identity Verification

Prior to opening an account on PopeyeX and assessing the PopeyeX platform, PopeyeX will

mandatorily verify each customer's identity and screen each customer against local and

international blacklists and sanctions lists, PEP lists and adverse media. PopeyeX meticulously

adheres to its Know Your Customer/Customer Due Diligence procedures and guidelines. This

involves all necessary actions to ensure that its customers are real persons and that the risks

of money laundering, financing of terrorism and other financial crimes are properly identified

and mitigated.

PopeyeX undertakes due diligence of its customers prior to account opening and on an

ongoing basis throughout the business relationship. PopeyeX may refuse to open an account

or halt a customer's continued access to the PopeyeX platform if the customer does not meet

our initial or ongoing KYC requirements.

Establishment of Beneficial Ownership of Funds

PopeyeX is required under applicable legislation and/or regulation to identify the beneficial

owner of all transactions undertaken on the PopeyeX platform and/or funds held in a PopeyeX

account. No customer is permitted to act on behalf of a third party while transacting on

PopeyeX. PopeyeX considers all persons holding an account or transacting through PopeyeX to

be the beneficial owner of the funds held in a PopeyeX account or transaction executed

through PopeyeX. PopeyeX may halt a customer's continued access to the PopeyeX' platform if

the customer is found to be acting on behalf of third parties.

Enhanced Know Your Customer/Due Diligence

Enhanced due diligence is conducted when a customer is deemed as exposing PopeyeX to a

high AML risk and/or when a transaction appears to be potentially suspicious based on

well-defined red flag indicators. Our client relationship staff will request additional KYC

documents such as proof of source of the fund or additional identification documents as

may be necessary to appropriately mitigate the risk. In such cases, in-depth due diligence is

conducted outlining the expected and actual transaction behavior and the ongoing

monitoring of transactions that may reveal potentially suspicious activities. Senior

management approval is required prior to approving customers with high AML risk exposure.On-going Transaction Monitoring

On an ongoing basis, our platform enables us to analyze the transaction behavior of the

users while monitoring the volumes and frequency of their transactions. In addition to the

above, our tools enable us to identify the red flags based on different parameters we use for

risk profiling of our customer base such as:

● Occupation/profession

● Expected transaction volumes and frequency

● Age

● Nationality

● Location

● Source of FIAT currency

● Source and Destination of VDA

Customers deemed as having high AML risk exposure are subject to more stringent and

frequent ongoing transaction monitoring. PopeyeX maintains the use of systems to effectively

monitor its customers and all transactions executed through the PopeyeX platform. Suspicious

transactions or activity on PopeyeX are subject to investigation.

Internal Reporting of Unusual/Potentially Suspicious Transactions

All client relationship staff liaising with the client(s) for increased limits requests and

overseeing subsequent remittances in the client's account are required to report any

potentially/actual suspicious or unusual transactions to the MLRO using our internal reporting

system.

Reporting of Unusual/Suspicious Transactions/Activity

All PopeyeX staff are required to monitor, detect and report unusual/potentially suspicious

activities or transactions to the MLRO, who will in turn, conduct an in-depth investigation, and

determine whether an external report should be made to the relevant authorities.

Record Keeping

PopeyeX maintains a record of all information and documentation obtained from its

customers during the customer onboarding process and thereafter throughout the duration

of the relationship between PopeyeX and the customer. Records maintained by PopeyeX

include customers' identification documents, transaction data, and any other related

documents. Records are retained as long as the customer holds an account with PopeyeX andsubsequently for a minimum period of eight years after the closure/redundancy of the

account, in accordance with Law 23 of 2015 and other relevant regulations.

Confidentiality of Records and Suspicious Transactions

All customer records and transactional information are kept confidential and in compliance

with Law 81 of 2019 on Panama Personal Data Protection at all times, and the customers are

not intimated if their transactions are considered suspicious and being reported to the MLRO

internally or are being filed as with regulatory authorities.

For any queries the MLRO can be contacted at [email protected]