KYT Policy

1.Introduction

GenesisXchange, the cryptocurrency platform based in Lithuania, is dedicated to upholding regulatory compliance and ensuring a secure trading environment through a robust Know Your Transaction (KYT) Policy. This framework outlines the procedures that the company will follow to prevent illicit activities, bolster due diligence, and adhere to the relevant laws and regulations in Lithuania.

2.AML Compliance

GenesisXchange is committed to AML compliance through the following actions:

Adhere to the Lithuanian AML/CTF Act and regulations, promptly incorporating any updates.

Conduct ongoing risk assessments to identify and mitigate potential money laundering risks.

Monitor transactions that may indicate layering or structuring activities.

3.User Onboarding

GenesisXchange pledges to adhere to the following procedures during the onboarding of clients:

  1. Conduct thorough customer due diligence (CDD).
  2. Verify customer identity using reliable sources, in compliance with Anti-Money Laundering (AML) regulations.
  3. Collect comprehensive information, including proof of identity, residential address, and source of funds.

4.Wallet Surveillance

The company will implement the following measures for continuous wallet monitoring:

  1. Continuously monitor client wallets to detect unusual or suspicious activity.
  2. Utilize automated tools to track transactions, with a focus on large or rapid fund movements.
  3. Regularly update and review wallet information to ensure accuracy and relevance.

5.Blockchain Analysis Technology Integration

To enhance blockchain analytics, GenesisXchange shall:

Integrate advanced technology solutions.

Utilize tools to trace the source and destination of funds, identifying high-risk transactions.

Stay informed about emerging threats and vulnerabilities in the cryptocurrency space through continuous training and updates on technological features.

6.1.Cryptocurrency Asset Monitoring

GenesisXchange shall extend KYT to monitor transactions involving all cryptocurrency assets:

  1. Ensure a holistic approach to transaction surveillance.
  2. Detect patterns of high-risk activity and prevent transactions involving addresses listed on sanction lists.

6.2.Real-time Alerts and Compliance

  1. Configure real-time alerts based on the organization’s AML compliance policies.
  2. Ensure that the monitoring system provides alerts for transactions involving sanctioned addresses and potential threats.
  3. Regularly review and update alert configurations based on emerging risks and regulatory changes.

6.3.Entity Address Monitoring

Monitoring shall cover all addresses controlled by an entity:

  1. Gather real-time intelligence on the source or destination of funds.
  2. Leverage KYT for vetting users within the platform, enhancing overall security and compliance measures.

6.4.Illicit and Legitimate Services

Monitoring shall extend to both illicit and legitimate services:

  1. Implement comprehensive monitoring for illicit services, including darknet markets, scams, and ransomware.
  2. Scrutinize legitimate services such as merchant services, decentralized cryptocurrency exchanges, NFT platforms, and bridges.
  3. Regularly update the monitoring system to adapt to evolving trends in both illicit and legitimate crypto activities.

7.Reporting and Compliance

GenesisXchange commits to maintaining compliance and timely reporting:

  1. Maintain accurate records of customer transactions and KYC information.
  2. Report suspicious transactions promptly to the relevant authorities.
  3. Collaborate with law enforcement and regulatory bodies, providing necessary information for investigations.

8.Regular Audits

Internal audits shall be conducted periodically:

  1. Assess the effectiveness of KYT procedures through periodic internal audits.
  2. Engage third-party auditors to ensure an unbiased evaluation of compliance.
  3. Adjust policies based on audit findings to enhance the effectiveness of the KYT framework.

9.Data Protection and Privacy

The company acknowledges the importance of protecting customer data and privacy:

  1. Implement robust measures to safeguard customer information, ensuring compliance with data protection laws.
  2. Regularly conduct privacy impact assessments to identify and address potential risks to customer data.
  3. Provide transparent communication to customers regarding data collection, storage, and usage.

10.Incident Response and Reporting

In the event of a security incident, GenesisXchange commits to:

  1. Establish a robust incident response plan to address and mitigate the impact of security breaches promptly.
  2. Report security incidents promptly to regulatory authorities and affected customers in accordance with legal requirements.
  3. Conduct thorough post-incident reviews to identify areas for improvement in the incident response plan.

11.Continuous Policy Review and Updates

GenesisXchange recognizes the dynamic nature of the cryptocurrency industry and commits to:

Conduct regular reviews of the KYT policy to align with emerging regulatory requirements and industry best practices.

Implement updates promptly to address evolving risks, technological advancements, and changes in the regulatory landscape.

Communicate policy updates internally and to customers in a transparent manner.

12.Adopting and amending this Policy

This Policy may be amended at any time. Any change to this Policy must be approved and adopted formally by the Director.

 

Last updated: January 2024

Approved by Director

Costas Makrides