AML Policy

Wozinga's AML / CTF Policy

(Anti-Money Laundering & Counter Terrorism Financing Policy)

Wozinga Pty Ltd is reference to "Wozinga”, “We”, “Our”, “Us”, a private limited company incorporated with Australian Securities and Investment Commission (ASIC) Number 625841741. As a digital currency exchange provider that exchanges:

• Money (Australian Dollar) for digital currency
• Digital currency for money (Australian Dollar)

as part of operating a digital currency exchange business

Wozinga is registered to Australian Transaction Reports and Analysis Centre (AUSTRAC) with regulation registration number 100577317.

1. Anti-Money Laundering (AML)

Anti-money laundering (AML) refers to a set of procedures, laws or regulations designed to stop the practice of generating income through illegal actions. Though AML laws cover only a relatively limited number of transactions and criminal behaviors, their implications are extremely far-reaching.

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 requires regulated entities to collect information to establish a customer’s identity, monitor transactional activity, and report to AUSTRAC transactions or activity that is suspicious or involves large amounts of cash over $10,000. Our compliance program has:

  • Compliance officer: The appointment of a Senior Compliance Officer (SCO) who will
    supervise, manage and establish AML/CTF policy. SCO will ensure that appropriate
    policies, procedures and controls are in place for the organisation to be compliant with
    AML/CTF law and regulation, and be effective in identifying, managing and mitigating
    ML/TF risks.
  • Implementation of Customer due diligence through Know Your Customer (KYC)
    procedures, transaction reporting, ongoing monitoring, record keeping requirements and
    enhanced customer diligence if necessary.
  • Evaluate and assess AML related risk and formulate controls that mitigate it
  • Ongoing and updated compliance training program for our AML/KYC compliance team
    and employees.

Customer Due Diligence

In terms of money laundering controls, it means implementing adequate policies, practices and
procedures that promote high ethical and professional standards for dealing with customers and
are designed to prevent exchange from being used, intentionally or unintentionally, by criminal
elements. Customer due diligence includes not only establishing the identity of customers, but
also monitoring account activity to identify those transactions that do not conform with the
normal or expected transactions for that customer or type of account.

CDD includes:

  • Collecting and verifying customer identification information – for example, documents, data or other information obtained from reliable and independent sources;
  • Identifying and verifying the beneficial owner(s) of a customer;
  • Identifying whether a customer is a politically exposed person (PEP) or an associate of a PEP and taking steps to establish the source of funds used during the business relationship or transaction;
  • • Undertaking ongoing CDD and transaction monitoring; and
  • Obtaining information on the purpose and intended nature of the business relationship.

2. Know your Customer (KYC)

AML/CTF law and regulations allow individuals to be verified using two methods. The most
appropriate method depends on the way the customer engages with us.

Method 1 – original or certified copy documentary evidence of the identity data points required by either of the following:

  • One photographic identification document as listed below; or
  • Two non-photographic verification documents.

Method 2 – electronic verification:

  • Using third party providers to evidence identity through searches of authoritative
    databases

Method 1 – document verification process

The individual will be advised that they need to provide the original or certified copies of
appropriate documents.

Using Method 1, we will verify:
  • The full name of each individual; and
  • The residential address of the individual; or
  • The date of birth of the individual.
Where we use Method 1, we will retain a copy of the identity documents used to verify the identity of the individual.

Acceptable Primary Photographic Verification Documents

  • Driver’s license: (With Country/State, Number and Expiry date)
  • Passport: (With Country/State, Number and Expiry date)
  • National identity card (photographic): (With Country/State, Number and Expiry date)

 

Acceptable Non-Photographic Verification Documents

  • Financial Benefits Statement issued by the Government within the last 12 months
  • Rates or utility notice issued by a local government body or utility provider within the last
    three months
  • Other government issued documents containing the individual’s name and current address
  • Bank or credit card statements containing the individual’s name and current address
  • Payslip or letter from employer containing the individual’s name and current address
  • Other documentary evidence that is deemed to be equivalent to the above (approval required)

Method 2 - electronic verification process

We will collect the identity information, as set out above, and attempt to verify the information using our electronic verification provider.

As part of the electronic verification check, customers may be required to provide additional information, such as passport numbers, driving licence numbers and other information (e.g. visa numbers).

The electronic verification provider will either:

  • Confirm the identity of the individual (by verifying the full name and residential address from at least two or more separate data sources); and
  • Confirm the date of birth of the individual from at least one data source; or
  • Advise that they are unable to verify the full name, residential address and date of
    birth of the individual.

If the electronic identification verification provider is unable to verify the identity of the individual, we will attempt to verify the identity of the individual from documents as set out in Method 1.

We will retain a copy of the original response from the electronic verification provider used to
identify the individual.

Private companies

Collection of identity information – Private Companies

We will collect the following information for private companies:

Information required.

  • Full name of the company as registered by the local regulator
  • Full address of the company’s registered office
  • Full address of the company’s principal place of business
  • Registered number issued to the company
  • Full names of all directors
  • Information set out in the individuals’ section in relation to ONE director
  • Full names of verifying officers and agents, title of their position or role held, their signatures and authorising document (e.g. an Authorised Signatories list)
  • Each ultimate beneficial owner’s full name and date of birth or full residential address

Verification of identity information

For verification of the company itself (i.e. verification of the name and registered number), we
will conduct a company search with the local/national company regulator.

Verification of verifying officers and agents

For verification of verifying officers and agents, we will collect an Authorised Signatories List
detailing the names, titles and, where required, specimen signatures of the verifying officers and
agents.

Verification of directors

We will also verify the identity of ONE director of the company in accordance with the process
for verifying individuals.

Verification of ultimate beneficial owners

We consider the ultimate beneficial owner to be any individual who is entitled (either directly or indirectly) to exercise 25% or more of the voting rights, including a power of veto, or who would be entitled on dissolution to 25% or more of the property of the company where 25% or more of the ultimate beneficial ownership cannot be established, all those that hold the position of senior managing official or equivalent will also be considered ultimate beneficial owners.

We will verify the ultimate beneficial owner/s of all private companies in accordance with the
process for verifying individuals.

Politically exposed persons (PEPs)

If any individual is identified as a foreign or domestic PEP, we will take the steps in accordance
with the process for verifying individuals.