Levex’s AML/KYC Policies and Procedures

This document outlines Levex’s policies and procedures regarding anti-money laundering (AML) and countering the financing of terrorism (CFT). It is intended for informational purposes only and does not constitute a legally binding agreement for Levex or any other individual or entity.

1. Levex’s Commitment to AML/KYC Compliance

Levex is dedicated to maintaining robust AML and KYC protocols. Our approach includes:

Conducting thorough due diligence on customers and individuals authorized to act on their behalf.
Operating with high ethical standards to minimize the risk of engaging in relationships that may facilitate money laundering or terrorism financing.
Cooperating with relevant authorities to mitigate financial crime risks to the greatest extent possible.

2. Risk Assessment and Mitigation

Our compliance framework consists of three layers:

Customer Identification (KYC): Verifying the identity of individuals and entities, including obtaining details on beneficial ownership in accordance with global standards such as those established by the Financial Action Task Force (FATF).
Risk-Based Screening: Conducting due diligence checks against government-provided sanctions lists, as well as other discretionary lists, to safeguard our reputation and our customers.
Ongoing Monitoring: Identifying and reporting suspicious activities that deviate from a customer’s expected transactional behavior by filing suspicious activity reports (SARs) with regulatory authorities.

Mitigating Identified Risks

Levex does not engage with individuals or entities flagged in designated sanctions lists.

3. New Products, Practices, and Technologies

We assess and address risks associated with:

The introduction of new products and business models, including alternative delivery mechanisms.
Emerging technologies, particularly those that promote anonymity, such as digital tokens.

4. Customer Due Diligence (CDD)

Levex does not support anonymous or fictitious accounts. We refuse transactions where there is reasonable suspicion of illicit financial activity and report such cases to the appropriate authorities.

Circumstances requiring CDD include:

Establishing a business relationship with a new customer.
Conducting a one-time transaction for a non-established customer.
Handling cryptocurrency transfers for new customers.
When there is doubt about the accuracy of previously provided information.
Identifying patterns of structuring transactions to evade AML measures.

Customer Identification Process: We require, at a minimum, the following details:

Full legal name, including any aliases.
Unique identification number (e.g., passport, national ID, or business registration number).
Residential or business address.
Date of birth or incorporation.
Nationality or jurisdiction of incorporation.

For corporate customers, additional documentation regarding governance, ownership structure, and controlling parties must be provided.

Verification Process: Levex verifies customer identities using independent and reliable sources. When customers appoint representatives, we ensure their authorization is valid through documented proof.

Beneficial Ownership Identification: If an entity has beneficial owners, we:

Identify the individuals with ultimate control.
Verify the existence and legitimacy of corporate structures.
Assess control mechanisms within legal arrangements (e.g., trusts and foundations).

Ongoing Transaction Review: Transactions that are unusually large, complex, or lack a clear economic purpose undergo enhanced scrutiny. Any inconsistencies are documented for regulatory purposes.

5. Enhanced Due Diligence (EDD)

For high-risk customers, including politically exposed persons (PEPs), Levex applies additional scrutiny by:

Requiring senior management approval for account setup and continuation.
Establishing the source of wealth and funds.
Increasing transaction monitoring frequency.

6. Restrictions on Cash and Bearer Instruments

Levex does not process payments using bearer negotiable instruments or cash.

7. Record Keeping

We maintain all customer records and transactions for at least five years, ensuring compliance with regulatory obligations.

8. Protection of Personal Data

Levex adheres to strict data protection policies to safeguard customer information.

9. Reporting Suspicious Transactions (STRs)

All identified suspicious activities are reported to the relevant authorities, and supporting documentation is retained for regulatory review.

10. Compliance, Auditing, and Employee Training

Our compliance program includes:

Continuous AML/CFT training for employees.
Periodic audits to ensure adherence to regulatory requirements.
Enterprise-wide risk assessments to address evolving threats in three phases:

Phase 1: Identifying inherent risks based on customer profiles, services, and geographic exposure.
Phase 2: Implementing control measures, including enhanced due diligence and transaction monitoring.
Phase 3: Evaluating residual risks after mitigation efforts.

Levex remains committed to upholding the highest standards of AML/KYC compliance to protect our business and customers from financial crime risks.

Levex Compliance Team