Compliance Disclosure
   2015/2/5 21:50:14

Prime Exchange AML/ATF/Sanctions Program


1. Purpose of Our Program

We have discretionarily established and implemented an Anti-Money Laundering, Anti-Terrorist Financing and Trade & Economic Sanctions Program (“AML/ATF/Sanctions Program” or “Program”) to ensure a robust, long-lasting and value-adding digital asset trading platform. We want to promote legal, transparent business activities and maintain a strong reputation among our customers, regulators and the digital asset industry.

2. Our Role and Activity

We are a global digital asset trading platform or marketplace, where traders come as buyers and sellers or commonly referred as market-makers and market-takers. For clarity, buyers and sellers trade with each other, and not with Prime Exchange. However, we provide a valuable service of settling trades and enabling withdrawals in digital assets.

Disclosure: Trading is Risky

The risk of loss in trading or holding digital assets can be substantial. You should therefore carefully consider whether trading is suitable for you in light of your financial condition.

3. Regulatory Landscape

We understand that regulatory bodies have taken a diverse approach to the laws and regulations regarding digital assets, including some characterizing or defining digital assets as virtual currency, crypto-currency or digital currency based on the context of certain business activities. As a trading platform or marketplace, we believe that bitcoin and litecoin (as well as other alternative-coins) are digital assets that are emerging as an innovative alternative asset class; and therefore, digital assets should not be called money or currency.

Disclosure: Digital Assets are Not Money Nor Fiat Currency

Prime Exchange does not view digital assets as money or fiat currency. Digital assets such as bitcoin and litecoin are NOT backed by any government or central bank.

We may at times have opinions of the different regulatory approaches taken by various government bodies; however, at all times, we will fully abide by rules and regulations of the respective countries. We regularly outreach to regulators and industry on the best approach to regulating digital asset businesses.

Disclosure: We Cooperate with Governments

While we may not welcome costly regulations in itself, we respect regulations and comply with applicable regulations. As good corporate citizens, we may be asked for information from law enforcement authorities and will assist if permissible by law. What this also means is that our platform is intended for law abiding customers. We welcome the opportunity to earn your business, and in return we require that you act legally and properly on our platform.

Furthermore, to promote a robust ecosystem, we have screened our customers (including beneficial owners) against the entities/persons on The United Nation Security Council Sanctions List. We also may screen against other lists on a discretionary basis to protect our reputation and customers.

Disclosure: We Do Not Accept Certain Customers

To maintain our strong reputation in the market and to abide by certain jurisdictions that have unique regulatory requirements, we have decided to not seek nor accept customers from certain jurisdictions such as Cuba, Iran, Sudan, Syria, North Korea, United States, Bangladesh, Bolivia, Ecuador and Kyrgyzstan. The latter four countries have presently banned activities involving digital assets. We simply don’t want to run afoul with various countries’ regulations.

4. Our AML/ATF Program

We have designed our Program to reasonably prevent money laundering and terrorist financing through a risk-based, multi-layer control system. The first layer includes a stringent customer identification program, including verifying the identity of our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-natural persons their entities’ beneficial owners/natural persons consistent to international standards such as the Financial Action Task Force (FATF). The second layer includes a risk based system to warrant additional customer due diligence. The third layer includes ongoing monitoring for suspicious activity. These are the primary components of our compliance program; however, the most important glue or connection to these layers are our leadership team and staff, including AML/Risk personnel that execute training, oversight and a sound compliance culture. If you have questions or require assistance with our customer due diligence controls, please do not hesitate to reach out to our 24/7 customer service representatives by email at [email protected]