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Anti-Money Laundering and Terrorist Financing Policy

Money laundering is a process or set of activities used by criminals to cover up the illegal origin of funds, i.e. funds acquired through criminal offense. Money laundering is always preceded by some illegal act.

People’s trust in the financial systеm can be severely compromised by the efforts of criminals and their accomplices to conceal the criminal origin of funds or to divert legal or illegal money for terrorist purposes.

Since 01.01.2020. COIN MARKET d.o.o. (hereinafter: CM) is obligated to apply the provisions of the Act on the Prevention of Money Laundering and Terrorist Financing (hereinafter: the Act). The Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) is responsible for supervising the application of the Act by obligors engaged in the provision of virtual and fiduciary currency exchange services and/or the provision of wallet custody services. CM is on the list of persons who have informed Hanfa that they perform the activities of providing virtual and fiduciary currency exchange services and/or activities of providing wallet custody services:

The success of CM’s business depends on the trust from their customers, employees and the public, and this trust is based on CM’s compliance with all relevant regulations. CM is committed to minimizing the risk of money laundering and terrorist financing (hereinafter: ML/TF) to the lowest possible level. The CM directorate is committed to ensuring that CM is fully compliant with all regulatory requirements to support public authorities in identifying criminal activities.

With this Policy, CM wishes to establish that they are fully committed to the fight against ML/TF, and these principles of operation are considered fundamental principles and values of CM compliance, which is in line with the basic principle of business in accordance with positive regulations and ethical standards.

CM implements at least the following measures to prevent ML/TF:

  • Customer due diligence in accordance with the Act and constant monitoring of the business relationship,
  • Reporting suspicious activities,
  • ML/TF risk assessment,
  • Protection, data storage and record keeping,
  • Establishing policies, controls and procedures for effective ML/TF risk management,
  • Employee education and internal communication of policies and procedures.

Customer due diligence and constant monitoring of business relationships

Customer due diligence measures inсlude customer identification and verification of customer’s identity based on official identity documents, collecting valid public documents and information obtained from reliable and independent sources, determining beneficial ownership, collecting information on the purpose and intended nature of the business relationship, other data in accordance with the Act including if necessary additional information on the source of funds, and continuous monitoring of business relationships.

Monitoring of potentially suspicious transactions, related transactions in given periods and continuous monitoring of business relationships is supported by automated verification systems based on collected data.

Reporting suspicious activities

In the event of noticing any information, fact or circumstance that could lead to money laundering or terrorist financing, the CM staff member shall immediately inform the anti-money laundering officer.

The anti-money laundering officer is obliged to inform the relevant authorities about any suspicious activity without delay within the prescribed time limits.

Risk assessment

CM conducts risk analysis periodically, at least once a year, especially before any significant changes in business procedures and business practices and before the introduction of new products, technology, delivery channels and externalized activities.

The risk analysis takes into account the information obtained from the analysis of the customer, client, transaction and documentation database and the expert opinion of CM staff.

Protection, data storage and record keeping

CM is obliged to keep data, information and documentation collected in the implementation of the Act and bylaws adopted on the basis thereof. In accordance with the Act, CM keeps data on clients, transactions, documentation and all reports related to the business relationship with the client.

Policies, controls and procedures for effective ML/TF risk management

Written policies, controls and procedures for mitigation and effective risk management adopted by CM inсlude the objectives, scope and mode of operation of the systеm, organizational structure, powers and responsibilities of the anti-money laundering officer and deputies, due diligence measures, establishment of reporting lines, risk management models and employee training.

CM coordinates policies, controls and procedures for the effective management of ML/TF risks in accordance with business needs and requirements, and regulatory changes without delay.

Employee education and internal communication of policies and procedures

CM undertakes to take all necessary appropriate measures to ensure that its staff are familiar with the basic concepts of money laundering and terrorist financing, and in particular with the concepts of customer due diligence and implemented Anti-ML/TF policies, controls and procedures.

Final provisions

This abbreviated version of the Policy enters into force on the day of its publication. With the entry into force of any changes to this Policy, the previous version will be repealed with effect from the date of entry into force of the latter.