AML Policy


1. Purpose

369 Exchange (“369 Exchange,” “Company,” “we,” “us,” or “our”) is committed to preventing money laundering, terrorist financing, fraud, sanctions evasion, and other financial crimes.

This AML Policy establishes the framework through which 369 Exchange complies with applicable:

  • Anti-Money Laundering (AML) laws

  • Counter-Terrorist Financing (CTF) regulations

  • Know Your Customer (KYC) requirements

  • International sanctions obligations

All users must comply with this Policy when using the Services.


2. Regulatory Commitment

369 Exchange applies risk-based compliance principles aligned with international standards including:

  • Financial Action Task Force (FATF) recommendations

  • Global AML best practices

  • Applicable financial crime regulations in operating jurisdictions

The Exchange maintains internal controls designed to detect and prevent illicit financial activity.


3. AML Compliance Program

369 Exchange maintains an AML Compliance Program consisting of:

  • Customer Identification Program (KYC)

  • Risk-based customer assessment

  • Transaction monitoring systems

  • Suspicious activity reporting

  • Sanctions screening

  • Record keeping

  • Staff compliance training

  • Independent compliance review


4. Know Your Customer (KYC)

4.1 Identity Verification

Users must complete identity verification prior to accessing certain services.

Verification may include:

  • Government-issued ID

  • Selfie or biometric verification

  • Proof of address

  • Phone/email confirmation

  • Source of funds verification

The Exchange may require enhanced verification at any time.


4.2 Risk-Based Customer Due Diligence

Customers are classified according to risk level:

  • Low Risk

  • Medium Risk

  • High Risk

Risk evaluation considers:

  • Geographic location

  • Transaction behavior

  • Source of funds

  • Trading patterns

  • Regulatory exposure


4.3 Enhanced Due Diligence (EDD)

Additional verification may be required for:

  • High-volume traders

  • Politically Exposed Persons (PEPs)

  • High-risk jurisdictions

  • Institutional accounts

  • Suspicious activity cases

EDD may include financial documentation and ongoing monitoring.


5. Sanctions Compliance

369 Exchange strictly prohibits access by individuals or entities subject to sanctions.

Screening includes:

  • OFAC sanctions lists

  • United Nations sanctions lists

  • EU sanctions lists

  • Other applicable government watchlists

Accounts connected to sanctioned persons may be immediately frozen.


6. Prohibited Activities

Users may NOT use 369 Exchange for:

  • Money laundering

  • Terrorist financing

  • Fraud or scams

  • Darknet market activity

  • Ransomware payments

  • Sanctions evasion

  • Human trafficking financing

  • Illegal gambling payments

  • Market manipulation tied to criminal proceeds

Violation results in immediate enforcement action.


7. Transaction Monitoring

369 Exchange utilizes automated monitoring systems designed to detect:

  • Unusual transaction patterns

  • Structuring or layering behavior

  • Rapid asset movements

  • Suspicious wallet interactions

  • High-risk blockchain exposure

  • Mixing or obfuscation attempts

Transactions may be delayed or blocked pending review.


8. Suspicious Activity Reporting

Where suspicious activity is identified, 369 Exchange may:

  • Conduct internal investigation

  • Request additional documentation

  • Restrict account access

  • Freeze assets

  • File Suspicious Activity Reports (SARs) with authorities

Users may not be notified where prohibited by law.


9. Record Keeping

369 Exchange maintains records including:

  • Customer identification data

  • Transaction history

  • Account activity logs

  • Compliance investigations

Records are retained for the legally required period.


10. Ongoing Monitoring

Customer relationships are continuously monitored to ensure:

  • Information remains accurate

  • Risk classification remains appropriate

  • Activity aligns with expected behavior

Accounts may be re-verified periodically.


11. Reporting Obligations

369 Exchange cooperates with:

  • Law enforcement agencies

  • Financial regulators

  • Compliance authorities

Information may be disclosed when legally required.


12. Employee Compliance & Training

Employees receive ongoing AML training covering:

  • Financial crime detection

  • Fraud prevention

  • Reporting obligations

  • Regulatory compliance standards

Access to sensitive data is strictly controlled.


13. Account Restrictions & Enforcement

369 Exchange reserves the right to:

  • Suspend accounts

  • Restrict trading

  • Freeze funds

  • Terminate services

without prior notice where AML risks are identified.


14. User Responsibilities

Users agree to:

  • Provide truthful information

  • Maintain updated identification records

  • Respond to compliance requests

  • Use funds derived from lawful sources

Failure to comply may result in account closure.


15. Risk-Based Approach

369 Exchange applies a dynamic risk-management model considering:

  • Transaction size

  • Asset type

  • User behavior

  • Geographic exposure

  • Blockchain analytics

Controls may evolve as risks change.


16. Policy Updates

This AML Policy may be updated periodically to reflect:

  • Regulatory developments

  • Emerging financial crime risks

  • Operational improvements

Continued use of Services constitutes acceptance.


17. Compliance Contact

369 Exchange Compliance Department
Email: compliance@369exchange.com
Website: https://369exchange.com

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