AML Policy

Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Policy

Website: https://milways.io Contact Email: info@milways.io 1. Introduction 1.1 Purpose The purpose of this Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Policy (the "Policy") is to set out the standards and principles by which Milways Crypto ("the Company") operates to prevent money laundering and terrorist financing, in accordance with the laws and regulations of the Hong Kong Special Administrative Region ("Hong Kong SAR"). 1.2 Scope This Policy applies to all employees, officers, directors, agents, and any other individuals or entities acting on behalf of the Company (collectively, "Personnel"). It also applies to all clients, customers, and users of the Company's services ("Clients"). 2. Legal and Regulatory Framework 2.1 Applicable Laws and Regulations The Company complies with the following laws and regulations: Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) (Cap. 615) Organized and Serious Crimes Ordinance (OSCO) (Cap. 455) United Nations (Anti-Terrorism Measures) Ordinance (UNATMO) (Cap. 575) 2.2 International Standards The Company adheres to international standards and best practices, including the Financial Action Task Force (FATF) Recommendations. 3. AML and KYC Procedures 3.1 Customer Due Diligence (CDD) 3.1.1 Identification and Verification The Company requires all Clients to provide the following information for identity verification: Full Name Date of Birth Nationality Government-issued Photo Identification (e.g., passport, national ID card, or driver’s license) Proof of Address (e.g., utility bill or bank statement not older than three months) 3.1.2 Enhanced Due Diligence (EDD) For Clients posing a higher risk, such as Politically Exposed Persons (PEPs) and those involved in Correspondent Banking relationships, the Company will conduct Enhanced Due Diligence (EDD), including: Obtaining additional information on the client and the intended nature of the business relationship Updating more regularly the identification data of client and beneficial owner Conducting enhanced ongoing monitoring of the business relationship 3.2 Ongoing Monitoring The Company will continuously monitor Client transactions to detect and report suspicious activities. This includes: Real-time monitoring of transactions Regular reviews of Client information and transactions Identification and reporting of suspicious activities to relevant authorities 3.3 Record Keeping The Company will maintain records of all identification documents, transaction records, and CDD measures for a minimum period of six years. These records will be readily available for inspection by regulatory authorities upon request. 4. Risk Assessment 4.1 Risk-Based Approach (RBA) The Company employs a Risk-Based Approach (RBA) to assess and manage money laundering and terrorist financing risks. This involves: Identifying and assessing the risks associated with Clients, transactions, and services Implementing appropriate measures to mitigate identified risks Regularly reviewing and updating risk assessments and mitigation measures 4.2 Risk Categorization Clients and transactions are categorized based on their risk levels: Low Risk Medium Risk High Risk 5. Reporting Obligations 5.1 Suspicious Activity Reports (SARs) Personnel must promptly report any suspicious activities to the Company’s Compliance Officer. The Compliance Officer will assess the report and, if necessary, file a Suspicious Activity Report (SAR) with the relevant authorities. 5.2 Legal Obligations The Company is legally obligated to: Report suspicious transactions to the Joint Financial Intelligence Unit (JFIU) Cooperate with law enforcement and regulatory authorities 6. Compliance and Training 6.1 Compliance Officer The Company appoints a Compliance Officer responsible for overseeing the implementation and enforcement of this Policy. The Compliance Officer's duties include: Ensuring compliance with AML and KYC laws and regulations Conducting regular audits and reviews of the Company’s AML and KYC procedures Providing training and guidance to Personnel 6.2 Training and Awareness The Company provides ongoing AML and KYC training to all Personnel. This training includes: Understanding AML and KYC obligations Recognizing and reporting suspicious activities Adhering to the Company’s AML and KYC procedures 7. Sanctions and Disciplinary Actions 7.1 Non-Compliance Any Personnel found to be non-compliant with this Policy may face disciplinary actions, including termination of employment. Clients who fail to comply with the Company’s AML and KYC requirements may have their accounts suspended or terminated. 7.2 Reporting to Authorities The Company reserves the right to report any non-compliant activities to relevant authorities without prior notice to the involved parties. 8. Amendments and Updates 8.1 Policy Review This Policy will be reviewed and updated regularly to ensure compliance with applicable laws and regulations. Any amendments will be communicated to all Personnel and Clients. Milways Crypto Email: info@milways.io