AML/CTF & KYC Policy

Cryptomo ("Cryptomo", "we") is committed to preventing our service from being used for money laundering, terrorism financing, proliferation financing, sanctions evasion, scams or other crime. This policy summarises how we meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the AML/CTF Rules (together, the AML/CTF laws), and Australian sanctions laws.

1. Our AML/CTF program

• A written AML/CTF program based on an assessment of the money laundering and terrorism financing risks of our services, customers, coins and countries, reviewed regularly and whenever our services change.
• A compliance officer responsible for the program, who reports to our senior management.
• Staff training and screening, and independent reviews of the program.
• Records kept securely for at least 7 years.

2. Knowing our customers (KYC)

Our customers are the merchants who use Cryptomo. Before we credit payments to a balance or process a withdrawal, and whenever we consider it necessary, we identify and verify:

• Individuals and sole traders: full name, date of birth and residential address, verified with a government-issued photo ID or reliable electronic sources, and the ABN where one is held.
• Companies and other entities: legal name, ACN/ABN or overseas registration, registered and business address, directors, and every beneficial owner who owns or controls 25% or more, plus the people who act for the business.
• The business itself: what you sell, your website, expected payment volumes and, where needed, the source of funds or wealth.

We apply enhanced checks to higher-risk customers, including politically exposed persons, businesses connected with high-risk countries, and unusual or large payment activity. We keep customer information up to date and may ask you to verify again.

3. Sanctions

We do not provide services to people or businesses listed on the DFAT Consolidated List or subject to Australian autonomous or United Nations sanctions, or to anyone located in a comprehensively sanctioned country or region. We screen customers when they sign up and on an ongoing basis. Funds linked to sanctioned persons are frozen and reported as the law requires.

4. Monitoring payments

We monitor incoming payments and withdrawals for activity that is unusual for a merchant, such as sudden changes in volume, many small payments that appear designed to avoid checks, or funds from wallets associated with crime, mixers or sanctioned persons. We may ask merchants about their customers and transactions, hold funds while we review them, return funds to their source where lawful, or refuse a transaction.

5. Travel rule

When we transfer virtual assets on behalf of a merchant (for example a withdrawal to another provider), we collect, keep and, where required, pass on information about the sender and the receiver, as the AML/CTF laws require.

6. Reporting

We report suspicious matters and other reportable transactions to AUSTRAC as the AML/CTF laws require. The law prohibits us from telling anyone that we have made, or are considering making, a report ("tipping off"). This means we may not be able to explain why we have delayed, refused or ended a service.

7. What we may do

To meet these obligations we may refuse to open an account, ask for more information, delay or refuse a payment, payout or withdrawal, freeze funds, or close an account. Our Acceptable Use Policy lists businesses we do not support.

8. Your part

Please give us accurate information, tell us when it changes, and do not try to avoid our checks, for example by splitting payments, using someone else's account or hiding who owns your business. Doing so can be a criminal offence.

9. Contact

Questions about this policy: mail@cryptomo.net (subject "Compliance").