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1.1 Mether's Unwavering Commitment: Mether ("Company," "we," "our," or "us") is dedicated to protecting the integrity of global financial systems. As a digital asset platform, we recognize the critical importance of preventing money laundering, terrorist financing, and all forms of illicit activities.
1.2 Policy Purpose: This Enhanced Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ("Policy") outlines our comprehensive framework for identifying, assessing, and mitigating risks associated with financial crime. It establishes mandatory procedures for customer due diligence, transaction monitoring, suspicious activity reporting, record-keeping, staff training, and ongoing compliance.
2.1 Binding Nature: This Policy in connection with the "Account Security Policy"(ASP) and "Prohibited Activities Policy"(PAP) is binding on all individuals and entities interacting with Mether, including:
i. Customers: Individuals or entities holding accounts or transacting on Mether's platform ("Platform").
ii. Users: All individuals accessing the Platform.
iii. Employees: All Mether personnel.
iv. Agents & Partners: Third-party entities acting on behalf of Mether.
2.2 Jurisdictional Compliance: Mether operates globally and adheres to AML/CFT requirements in all relevant jurisdictions, including FATF recommendations, USA PATRIOT Act, PMLA 2002, EU AML Directives, and other national regulations.
3.2 Risk-Based Approach: We implement a risk-based approach, tailoring controls based on risk levels. This includes:
3.1 Comprehensive Risk Assessment: Mether conducts ongoing risk assessments to understand money laundering and terrorist financing risks associated with our platform, customers, and geographic locations.
i. Customer Risk Profiling: Categorizing customers based on geographic location, transaction activity, and business type.
ii. Service Risk Assessment: Assessing the risks associated with different products and services offered.
iii. Geographic Risk Assessment: Evaluating risks related to operating in specific countries or regions.
3.3 Mitigation Strategies: We implement controls and mitigation measures, including: Enhanced Due Diligence (EDD)
i. Transaction Monitoring
ii. Sanctions Screening
iii. Suspicious Activity Reporting (SAR)
4.1 EDD Triggers: Mether will conduct EDD when customers pose a higher risk, based on factors such as:
i. High-Risk Jurisdictions: Jurisdictions which are marked as high risk areas by the international and national regulators. This also includes the high risk zones identified by the risk assessment team of the platform.
ii. Politically Exposed Persons (PEPs): In addition to standard due diligence, customers identified as PEPs will be subject to enhanced scrutiny,including verification of source of income and ongoing monitoring of transactions for any signs of corruption or illicit activity.
iii. Cash-Intensive Businesses: The account which handles a lot of cash transaction in regular and irregular manner which are vulnerable to money laundering in order to mix illicit money with legitimate money.
iv. High-Value Transactions: The transactions where high volume of amount is being transacted which requires proper authentication and verification in order to comply with the regulations of international standard.
v. Unusual Transaction Patterns: Transactions taking place in such a pattern where it creates a suspicion, such account has to go through EDD procedure.
vi. Trigger-Based EDD Refresh: Enhanced Due Diligence will be automatically refreshed upon the occurrence of specific triggers, including but no limited to changes in multiple IDs,transaction patters, transaction originating from or destined for newly designated high risk jurisdictions or varying jurisdictions, or the emergence of adverse media reports concerning the amount holder.
vii. Ongoing Monitoring: Customers accounts will be continuously monitored based on their risk levels. high-risk accounts will be subject to more frequent and detailed scrutiny, including transaction monitoring, review of accounts activity, and periodic updates to KYC and EDD information.
4.2 EDD Measures: EDD measures may include:
i. Origin of funds
ii. Source of Funds Verification
iii. Enhanced Monitoring
iv. Senior Management Approval
4.3 Specific Measures for Investment Activities: To address risks associated with investment activities, Mether will implement the following:
i. Mandatory Investment Plans Disclosure: Customers engaging in investment activities must provide detailed purpose, disclosures and strategy about their investment plans, including the source of funds, intended investment strategies, and expected returns when required for verification. The platform will conduct advanced monitoring and verification of these plans to ensure they align with the customers declared intentions and risk profile.
ii. Independent Verification of Investment Details: Mether will independently verify the legitimacy of investment plans through available means, such as reviewing supporting documentation, consulting industry experts, and conducting on-site inspections.
iii. Advanced Transaction Monitoring for Investment Activities: Implement enhanced transaction monitoring rules to detect unusual patterns or anomalies indicative of fraudulent investment schemes.
iv. Regular Account Reviews and Risk Reassessment: Conduct regular reviews of customer accounts to reassess their risk profiles based on ongoing activity and changes in circumstances.
5.1 Automated Monitoring System: Mether uses an automated transaction monitoring system that operates 24/7 to analyze transaction patterns, identify anomalies, and generate alerts.
5.2 Manual Review: Our Compliance Team investigates suspicious activities, gathers additional information, and liaises with law enforcement when necessary.
5.3 Enhanced Scenarios for Transaction Monitoring: In addition to standard AML scenarios, Mether's monitoring system will include the following enhanced scenarios:
i. Investment Activities Monitoring: Automated monitoring rules will be implemented to detect patterns indicative of fraudulent investment schemes, such as pyramid schemes or Ponzi schemes.
ii. Account Aggregation Monitoring: Monitor for patterns where funds are aggregated from multiple accounts into a single account, especially if the funds are then transferred out of the system quickly.
iii. Early Warning Systems for High-Risk Customers: Implement a system to proactively monitor high-risk customers and identify potential compliance violations or suspicious activities.
iv. Review of Account Activity Following a Notice of Account Suspension: When an account is flagged for suspension, ensure that all related accounts are reviewed for similar suspicious activity.
6.1 Mandatory EDD Requests for Suspicious Activities: When a customer's account is flagged for suspicious activity including but not limited to any of the above stated reasons, Mether will require immediate submission of detailed EDD documentation and information.
6.2 Communication Audit Trails: Maintain a comprehensive log of all communication with the customer to track due diligence efforts and responses.
6.3 Escalate Non-Compliance to Legal: Designate a clear escalation path to the legal department in cases where customers fail to comply with requests for EDD documentation or information.
7.1 Reporting Obligations: Mether reports suspicious transactions to the appropriate Financial Intelligence Unit (FIU).
7.2 Internal Procedures: All employees must report any suspected money laundering or terrorist financing activities to the Compliance Officer.
7.3 Enhanced Reporting Scenarios: In addition to standard reporting scenarios, Mether's compliance team will be trained to report the following:
i. Attempts to Evade EDD: Report any attempts by customers to evade EDD requirements, such as providing false information or attempting to circumvent verification procedures.
ii. Unsubstantiated Investment Plans: Report any investment plans that lack credible evidence or supporting documentation.
iii. Concerns about Potential Fraud: Report any concerns about potential fraudulent activities, such as investment scams or Ponzi schemes.
8.1 Record Retention: Mether retains records as required by laws and regulations.
8.2 Data Security: We employ safeguards to protect customer information.
9.1 Ongoing Training: Mether provides ongoing AML/CFT training to all relevant personnel.
9.2 Training Content: Our training covers:
i. Current AML/CFT regulations
ii. Risk assessment
iii. CDD procedures
iv. Transaction monitoring
v. Suspicious activity reporting
10.1 Audits: Mether engages third-party auditors to review our AML/CFT program.
10.2 Internal Reviews: The Compliance Team performs internal reviews to ensure effectiveness.
11.1 Prohibited Transactions: Mether prohibits transactions with sanctioned entities and individuals.
11.2 Sanctions Screening: We use screening procedures to prevent transactions with sanctioned parties.
Mether maintains an open relationship with law enforcement and regulatory agencies.
This Policy will be reviewed and updated to reflect changes in laws, regulations, and business operations.
For inquiries, contact our Compliance Department at Legal@m20chain.com.
15.1 No Guarantees Against Fraud: Mether is committed to providing a secure platform, but no measures can completely eliminate the risk of fraud or illicit activities. Users acknowledge that they use the platform at their own risk.
15.2 Disclaimer of Liability: Mether shall not be liable for any losses, damages, or expenses incurred by users as a result of fraudulent or illicit activities conducted on the platform.
15.3 Reporting Suspected Fraud: Users are encouraged to promptly report any suspected fraudulent or illicit activities to Mether, who will investigate and take appropriate action.
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