Anti Money Laundering (AML)

What Is Anti Money Laundering?
Anti money laundering refers to a set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income. Though anti-money-laundering laws cover a relatively limited range of transactions and criminal behaviors, their implications are far-reaching. For example, AML regulations require that banks and other financial institutions that issue credit or allow customers to open deposit accounts follow rules to ensure they are not aiding in money-laundering.
 

Anti-Money Laundering (AML) POLICY &
Combating the Financing of Terrorism (CFT) POLICY
Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) are set
of laws, regulations, and procedures for providing protection to all end users from illegal
activities, maintaining legal and regulatory compliance helping to prevent detect and
investigate fraud, money laundering (illegally obtained funds as legitimate income) and/or
other criminal activities or misuse of services.
The legal bases for this processing are: the performance of a contract between you and
us and/or taking steps, at your request, to enter into such a contract and the legitimate
interests of ours and/or those of third-parties, namely to prevent, detect and investigate
fraud, criminal activity and/or other misuse of the services. In addition to this, the
processing of personal data is necessary for compliance with the legal obligation that
DigiDinar is subjected to, namely in order to comply with anti-money laundering and anti-
terrorist financing laws.
Purpose
Digidinar has implemented this Anti-Money Laundering Policy and Procedures - The
“AML Policy” to prevent money laundering and terrorist financing in relation to its
business. We require all of our directors, officers, employees, contractors, and agents
(“Representatives”) to read, understand, and follow this AML Policy in the course of
performing these services. We also expect our users to adopt and follow appropriate risk-
based compliance standards to prevent money laundering and the financing of terrorism
in relation to the services that they perform for us.
Digidinar prohibits all representatives and business partners from engaging in money
laundering and/or terrorist financing in relation to the Company’s business. Digidinar and
its Representatives and Business Partners in the course of performing services for
Digidinar must comply with all anti-money laundering (“AML”) and combating the
financing of terrorism (“CFT”) laws and regulations applicable to the Company’s business
anywhere in the world.
Compliance Program
In an effort to ensure compliance with applicable AML/CFT standards, Digidinar has
implemented the following:
(i) Development of internal policies, procedures, and controls;
(ii) Designation of a Money Laundering Reporting Officer;
(iii) Employee training program; and
(iv) An independent audit function to test the compliance program.
Digidinar has implemented a customer identification program (also referred to as “know-
your-client” or “KYC” program) set forth in this AML & CFT Policy to understand our
customers/account holders and their source of funding.
Digidinar is based in the State of Kuwait where it operates a digital currency trading
platform licensed by the Ministry of Commerce and Industry (MOCI). Digidinar is
committed to complying with applicable AML/CFT laws and regulations of the State of
Kuwait consistent with its obligations under its Ministry of Commerce and Industry
(MOCI) license. All Representatives and Business Partners must understand that
compliance with applicable Kuwaiti AML/CFT laws and regulations is critical so that
Digidinar can continue to maintain its Ministry of Commerce and Industry (MOCI)
License.

This includes, but is not limited to:
o Establishing internal policies, procedures and controls that strive to combat any
attempted use of Digidinar for illegal or illicit purposes to ensure our customers basic
protections under consumer protection laws;
o Complying with the applicable regulations and guidance set forth by the National Bank of
Kuwait (NBK)
o Executing Know Your Customer (“KYC”) procedures on all users;
o Employing a Chief Compliance Officer (“CCO”) who is responsible for the implementation
and oversight of our AML Program;
o Filing Suspicious Activity Reports (“SARs”);
o Filing Currency Transaction Reports (“CTRs”);
o Maintaining comprehensive records of orders and transfers;
o Performing regular, independent audits of our AML Program;
o Following record retention requirements; and
o Implementing a formal and ongoing compliance training program for all new and existing
staff members.
o Certain principals of Digidinar remain subject to international AML/CFT laws and
regulations irrespective of the location. At this stage, Digidinar is not engaged in any
business in the State of Kuwait nor does it maintain or intend to allow clients/users to
gain access to its digital currency trading platform or related products or services. Should
you learn of any such activities that contradict Digidinar’s position, you must notify the
MLRO so that he and/or she can determine whether any registration, reporting, record
keeping, and/or other AML/CFT compliance program requirements will apply to Digidinar
under the State of Kuwait laws and regulations in addition to that which are already
mentioned in this AML/CFT Policy.
o Digidinar Compliance Officer is responsible for developing and enforcing the policies and
procedures of our AML Program. Digidinar Compliance Officer is required to report any
violations of our AML Program directly to our CEO and Board Members. In addition,
Digidinar Compliance Officer is responsible for recording and filing SARs, CTRs and
performing a AML Program audit at least annually.
Transaction Reports
We file Suspicious Activity Reports if we suspect or have reason to suspect suspicious
activities have occurred on Digidinar.com. A suspicious transaction is often the one that
is inconsistent with a customer’s known and legitimate business, or personal activities.
Digidinar compliance department will perform transaction monitoring to assist to identify
unusual patterns of customer/user activity. Digidinar Compliance Officer will maintain all
records and review supporting documentations to investigate suspicious activities to
determine if sufficient information has been collected to justify the filing of a Suspicious
Activity Reports (SAR)

Copyright © 2019 DigiDinar | All Rights Reserved

Account Registration Process
Effective “Customer Due Diligence” or “Know-Your Customer” (KYC) measures are
essential for the management of AML/CFT risk. Proper due diligence is also relevant in
the context of Digidinar relationships with certain third-party vendors. Digidinar has the
right but is not limited to obtaining the following while registering an individual and or
company account:
o Full legal name and any other names used;
o Full Permanent Address
o Date and Place of Birth;
o Nationality;
o Passport number;
o National ID Card Details;
o Telephone Number
o Username and Email Address;
o Occupation;
o Employer’s name and address (if self-employed, the nature of the self-employment);
o Type of account, and nature and volume of anticipated business
o Past, current, and prospective dealings with the Company (If any);
o Source of funds; and
o Source of Securities.
Employee Training
Due to the importance of this policy and the procedures set forth Digidinar shall establish
and implement an employee training program. The purpose of the training program shall
be to familiarize relevant employees with Digidinar’s specific AML/CFT procedures and
provide instruction for recognition of suspicious activities.
Digidinar will ensure that employees are trained on the obligation to report suspicious
transactions to the respective responsible digidinar representatives. All relevant
employees and new hires must participate in this training. Digidinar representatives are
responsible for providing updated training to all staffs/employees as and when
necessary.

Independent Audits
Digidinar shall ensure independent and effective audits to Digidinar’s AML/CFT compliance
program on an annual basis. Digidinar shall appoint a qualified and objective third party to
conduct this audit.
All audits must involve appropriate testing Digidinar transactions as determined by the auditor. All
AML/CFT audit reports must be shared with Digidinar representatives, Compliance Officers and
Internal Legal Counsels (if any).
Recordkeeping
Digidinar shall keep and maintain internal records pertaining to the identity of each Business
Partner. Digidinar is committed to maintaining accurate records, and accounts in relation to its
business.
Please forward any queries to www.digidinar.com

Copyright © 2019-2020 DigiDinar By Kuwaiti Coin Limited | All Rights Reserved