KYC and AML/CTF policy

1. Introduction

Know Your Customer (KYC) and Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) procedures exist to keep financial services from being used for crime. They protect customers, the platform and the wider community.

This policy explains what we ask for, why we ask for it and what happens with the information. It applies to every account, whatever the amount.

2. What KYC is

KYC is the process of identifying a customer and confirming that the details they gave are true. In practice, it means matching your name, date of birth and address to documents that were issued by a trusted source.

It is carried out when you open an account and refreshed when your circumstances or risk profile change.

3. What AML/CTF is

AML/CTF covers the controls that stop criminals disguising the origin of money or using it to finance terrorism. They include assessing the risk each customer presents, monitoring transactions and reporting suspicious matters to the regulator.

In Australia, the regulator for these obligations is AUSTRAC, and we operate a written AML/CTF program that is reviewed on a regular basis.

The two work together. KYC answers the question of who a customer is, and AML/CTF controls answer the question of what is happening with their account over time.

4. Why we verify your identity

Verification does four jobs. It prevents fraud by making it harder to open an account in someone else's name. It protects your account from takeover. It allows us to meet the obligations that apply to us under Australian law. And it reduces the financial risk to every other customer.

5. Documents we may ask for

We only ask for documents that we actually use. Depending on your account, they include:

• Proof of identity: a current Australian driver licence, passport or equivalent government photo ID.
• Proof of address: a utility bill, bank statement or government letter issued in the last three months.
• A live check: a short selfie or liveness check to show that the person in the document is the person using the account.

Documents must be clear, in full, uncropped and unedited, and show your name as it appears on your account.

6. How verification works

1. Register: create your account and enter your basic details.
2. Provide data and documents: upload the items above using the secure form.
3. Automatic checks: software reads the document, checks for signs of tampering and compares the photo with your live check.
4. Manual review: if something cannot be confirmed automatically, a trained person looks at it.
5. Confirmation: you are told the result, and what to do next if more is needed.

Most customers are verified without anyone needing to contact them. If we do need something further, we say precisely what it is and why, and we give a reasonable time to provide it. You will not be asked to resend the same document repeatedly.

7. Enhanced due diligence

Some situations call for a closer look. Examples are large or unusual amounts, links to higher-risk countries, or activity that does not match the profile you gave us. In those cases we may ask for additional information such as source of funds or source of wealth, supported by documents like payslips, sale contracts or tax records.

Sometimes an extra check is nothing to do with you. A change in the rules, a new risk indicator or a routine review of existing customers can all prompt us to ask for a document that we already hold in an older form.

8. How long verification takes

Many checks complete within minutes. Some need a manual review, which may take one to three business days. The time depends on the quality of the documents, how closely they match your details, whether any further information is needed and how busy our team is.

9. Reasons verification may be declined or paused

• Documents that are expired, unreadable or only partly visible
• Details that do not match between documents and your account
• Signs of forgery or alteration
• Information we asked for that was not provided in time
• An account that is already linked to another person or to earlier fraud

If this happens we explain what went wrong where we are permitted to. You can send corrected documents or contact support.

10. Transaction monitoring

We monitor activity on the platform for patterns that are unusual for your account, for example rapid movement of funds in and out, many accounts using the same device, or payments from third parties. Monitoring is partly automated and partly done by analysts.

If we see something concerning we may restrict certain features, delay a withdrawal for review or ask you to explain. In certain cases the law requires us to report to AUSTRAC and not to tell you that we have done so.

Monitoring is not a judgement about you. Most alerts turn out to have an ordinary explanation, and a short conversation with support is usually enough to close them. We keep records of what we looked at and what we concluded, so you do not have to explain the same thing twice.

11. Your responsibilities

You must give us accurate, current and genuine information and documents, and tell us promptly when something changes, such as your address or your phone. Providing false information may lead to your account being closed, funds being frozen and, in serious cases, a report to the authorities.

Keep your documents current. If your licence or passport expires, or you move house, update your details so that your verification does not lapse and delay a withdrawal at a time you need one.

12. Data storage and protection

KYC records are stored in encrypted form, accessed only by staff who need them for their role and kept for the period the law requires, which is currently at least seven years after an account closes. How we handle personal information more broadly is described in our Privacy Policy.

13. Sharing of data

To carry out these checks we use specialist identity verification providers and IT service providers under contract. We may also share information with affiliated companies, and with regulators, law enforcement and courts where the law requires or allows it. We do not sell your verification data.

14. Compliance with requirements

Our program is designed to meet the obligations that apply to providers of digital currency and virtual asset services in Australia under the AML/CTF Act and the rules made under it, as administered by AUSTRAC. Where the provision of financial products falls within ASIC's remit, we also comply with the applicable financial services law.

This policy is reviewed at least once a year and whenever the law or our risk assessment changes. When a requirement changes in a way that affects customers, the page is updated and, where needed, you will be asked to confirm or refresh your details.

15. Contact

For questions about verification, AML/CTF or what we hold about you, contact [email protected]. Support is available Monday to Friday, 9:00 to 17:30 AEST/AEDT, excluding public holidays.