General AML/KYC Policy

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Effective:
29th August 2022

ComiBlock mission is to provide services on digital asset in the simplest and safest way to its customers. While ComiBlock remains liable, the AML/FT requirements and the « Know your customers » (KYC) practices can be delegated to a third party. ComiBlock works with a "KYC professional" third party. The third professional third party provides ComiBlock an up-to-date KYC tool.

Crypto Asset Service Provider

In order to provide such services, ComiBlock has partnered with the regulated Prime Broker FalconX a licensed Money Service Business registered with FinCEN in the United States and is required to comply with many financial services laws and regulations. FalconX maintains an Anti-Money Laundering Program subject to annual testing and aligned with Bank Secrecy Act requirements including Know Your Customer (KYC), Customer Identification Program (CIP), Surveillance, Training, and Sanctions Screening. Further, registered with the Malta Financial Services Authority Class 3 License Number VFA/07), which is subject to AML and Sanctions Program.

Such Partnerships require ComiBlock to be compliant with the regulations on Anti-Money Laundering and Combating the Financing of Terrorism (AML/FT).

AML/FT policy

Indeed, when acting as a counterparty in a transaction involving the acquisition or selling of crypto-assets, ComiBlock is subject to the obligations contained in the Directive on the Fight Against Money Laundering and the Financing of Terrorism (hereinafter, “ AML/FT ”).

The AML/FT Directive FATF’s R.15/INR.15 is implemented to mitigate such risks. In particular, FATF’s Travel Rule requires VASPs and other financial institutions to share relevant originator and beneficiary information alongside virtual asset transactions to prevent criminal and terrorist misuse. ComiBlock must comply with obligations contained in the regulation concerning the fight against money laundering and the financing of terrorism.

KYC procedure and tool

While ComiBlock remains liable, the AML/FT requirements and the « Know your customers » (KYC) practices can be delegated to a third party. ComiBlock works with a "KYC professional" third party. The third professional third party provides ComiBlock with an up-to-date KYC tool.
Such KYC procedure enables in the identification of ComiBlock customers through liveness detection. The third-party KYC procedure provides a comprehensive audit against international regulations on sanctioned, wanted, or convicted persons in association with economic & financial crimes (AML/CTF). Two steps are required, first identity proofing and second risk screening.
external delegation and use of a KYC tool do not exclude ComiBlock liability. For this reason, ComiBlock implemented an internal procedure to provide a high-level duty of care. The duty of care includes, but is not limited to, compliance with provisions of Applicable Monetary and Financial Code and the KYC policy in jurisdictions it operates by using reporting process and key performance indicators.

Internal measures

Trading products and goods regardless of whether they are tangible or virtual, such as crypto-assets, involves significant risk. For these reasons, ComiBlock has settled an internal procedure which is carried out by ComiBlock team. ComiBlock internal procedure includes a risk assessment policy managed by legal and technical experts.

ComiBlock risk assessment policy includes, but is not limited to, the following risks:

  1. market and liquidity risks,
  2. volatility and default risks,
  3. legal and tax risks.

ComiBlock Internal measures are compatible with applicable standards in the area of the fight against money laundering and the financing of terrorism.

The following measures represent the minimum guarantees provided by ComiBlock FATF standards framework:

  • The introduction and implementation of KYC practices.
  • Practices for carrying out additional due diligence on certain customers who represent a higher risk, such as politically exposed persons(PEP).
  • Submitting all transaction report to the Malta Financial Services Authority

ComiBlock has set up an internal control system to assess its procedures and to ensure that its policy complies with existing regulations (Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers, dated June 2022). The internal control is adapted to our size, nature, complexity and volume of our activities and provided with sufficient human resources. ComiBlock policy is continuously updated in the light of the results of any controls performed.

Legal contact

If you would like to find out more about how we manage risks at ComiBlock, please get in touch: compliance@comiblock.com

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