+61 458 706 306 daryabixe@gmail.com
Objective and the purpose of this policy is to ensure that Daryabi Exchange (referred to hereafter as “the Company”) adheres to Australian AML/CTF laws to prevent, detect, and report any activities related to money laundering or terrorism financing. This policy applies to all employees, agents, contractors, and associated entities of the Company. 2. Regulatory Framework This policy aligns with the requirements of the following legislation:
  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
  • Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1)
  • Any guidelines issued by the Australian Transaction Reports and Analysis Centre (AUSTRAC)
3. Customer Due Diligence (CDD) The Company adopts a risk-based approach to identifying and verifying customers, including:
  • Initial Verification: All customers must undergo identity verification, including full name, date of birth, and residential address.
  • Ongoing Verification: Customer identification information will be reviewed periodically to confirm validity.
  • Enhanced Due Diligence (EDD): Higher-risk customers (e.g., politically exposed persons, high-value transactions, or transactions from high-risk jurisdictions) will undergo enhanced due diligence.
3.1. Customer Identification Requirements The following documents may be required for individual or business verification:
  • Individuals: Passport, driver’s license, or government-issued ID.
  • Businesses: Proof of business registration, incorporation documents, and beneficial ownership information.
4. Transaction Monitoring The Company will implement a transaction monitoring program to detect unusual or suspicious activity. All transactions above AUD 10,000, as well as those that appear unusual or potentially suspicious, will be reviewed. 4.1. Suspicious Transaction Indicators
  • Transactions inconsistent with the customer’s financial profile.
  • Structuring transactions below reporting thresholds.
  • Transactions involving high-risk countries or individuals.
5. Reporting Obligations In compliance with AUSTRAC’s reporting requirements, the Company will:
  • Submit Suspicious Matter Reports (SMR): Any transactions or behavior deemed suspicious will be reported to AUSTRAC within 24 hours (if urgent) or 3 business days otherwise.
  • Threshold Transaction Reports (TTR): All cash transactions exceeding AUD 10,000 must be reported within 10 business days.
  • International Funds Transfer Instruction (IFTI) Reporting: International transfers, regardless of value, must be reported to AUSTRAC within 10 business days.
6. Risk-Based Approach (RBA) The Company will adopt a risk-based approach to AML/CTF compliance:
  • Risk Assessments: Regular risk assessments will identify high-risk customers, products, and services.
  • Mitigation Measures: Appropriate controls, including enhanced due diligence, additional monitoring, or refusal of service, will be applied based on the risk level.
7. Record Keeping The Company will maintain accurate records of:
  • Customer identification documents and verification steps.
  • All transactions processed.
  • Suspicious activity reports submitted to AUSTRAC.
  • All records will be retained for a minimum of 7 years.
8. Employee Training The Company will provide regular AML/CTF training to all employees, including:
  • Understanding of AML/CTF obligations and reporting processes.
  • Identification of suspicious activities and transactions.
  • Procedures for verifying customer identities and maintaining records.
9. Independent Review An independent AML/CTF audit will be conducted every two year to evaluate the effectiveness of this policy. The audit will review customer due diligence processes, transaction monitoring systems, and reporting compliance. 10. Consequences of Non-Compliance Failure to comply with this policy can lead to:
  • Disciplinary actions against employees, including termination.
  • Legal and financial penalties imposed by AUSTRAC.
  • Potential damage to the Company’s reputation and regulatory standing.
11. Policy Review and Updates This AML/CTF policy will be reviewed annually or as required by legislative changes. Updates will be made to ensure alignment with the latest AUSTRAC guidance and industry best practices. This policy is approved by the Board of Daryabi Exchange and is effective from the date of signing.