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AML Policy

AML Policy

Financial institutions and closely relatedentities (such as e.g. cryptocurrency exchanges) experience often attempts ofmoney laundering and terrorist financing. Money laundering is defined as theprocess where the identity of the proceeds of the crime are so disguised thatit gives the appearance of legitimate income. Terrorist financing is defined asthe process of providing support to individual or group terrorists. Withoutdirect terrorist financing, such activities as fund-raising, use and possessionand funding arrangements also falls under the definition of terroristfinancing.

MONEY 2EMONEY (a service/product of AjuBitLimited) pays thorough attention to any activities that may be consideredas money laundering or terrorist financing. M2EM (the MONEY 2 EMONEY) AML policy is designed to prevent moneylaundering by complying with Seychelles AML legislation along with Globalobligations including the need to have adequate systems and controls in placeto mitigate the risk of being used to facilitate the financial crime. Tominimize and mitigate the risk of money laundering and/or terrorist financing, M2EMimplemented effective internal measures and procedures:

    • Establishment of the identity of M2EM customer;

    • Assessment of risk;

    • Monitoring of the customer’s activities; and

    • Reporting of suspicious activities to respective authorities ifnecessary or asked hereby.


Establishment of the identity

Beforeany customer can access and benefit of M2EM services, identity of such customerhas to be established.

For M2EM tobe able to establish the identity of its customer, M2EM must obtain sufficientdata/documents/information from a (perspective) customer and verify suchdata/documents/information against independent sources. Customers that in theopinion of M2EM pose higher risk may be investigated more thoroughly which mayresult in requesting of additional information and taking longer term forverification of the identity of such customer. M2EM retains a right tore-establish the identity of the customer in cases where M2EM Limited sees itfit and in relation to that, request additional data/documents/information orrenew previously submitted.

Customer’sidentification information will be collected, stored, shared and protectedstrictly in accordance with M2EM Privacy Policy and related regulations.


Assessment of risk

Tomitigate and minimize the risks, M2EM has adopted a risk-based approach whichenables to identify, assess, and understand the money laundering and terroristfinancing risk to which AjuBit Limited is exposed, and take the appropriatemitigation measures in accordance with the level of risk. Risk based approachalso allows to pay most of the attention to the higher risk and allocate mostof the resources for mitigation of such risks.



To get toknow its customers, M2EM performs ongoing and retrospective monitoring.Monitoring performed by M2EM intends not to only to get to know the customer,but also to notice unconformities taking into comparison information submittedto M2EM by the customer or obtained by M2EM during establishment of theidentity and such customer’s actual activities using M2EM services and to catchany attempts of fraudulent, illegal or unlawful activity.

M2EM usesboth manual and automated solutions to track its customers’ transactions. M2EM mayuse other measures on case by case basis.

Eachsuspicious activity will be thoroughly investigated and, if necessary, reportedto the respective authorities or other restrictive measures taken to ensure no moneylaundering or terrorist financing activity is performed. M2EM is entitled torequest additional information/data/documents in relation to any transactionand the customer must follow the such request.


Reporting to the authorities

Followingits AML Policy and the applicable legal acts, M2EM, when necessary, will reportto the respective authorities of the activities that may be considered as moneylaundering and terrorist financing. M2EM will not disclose any informationabout such report to have been made and will not address any questions inrelation to that.


Compliance officer

M2EM hasthe assigned Compliance officer who is responsible for implementation of M2EM AMLpolicy, including but not limited to, of the above listed activities.