Anti-Money Laundering & Counter-Terrorism Financing Policy
1. Commitment
VESTEX is committed to complying with all applicable anti-money laundering (AML), counter-terrorism financing (CFT), and counter-proliferation financing (CPF) laws and regulations, including those applicable in the British Virgin Islands and other relevant jurisdictions. VESTEX will not knowingly facilitate money laundering, terrorist financing, sanctions evasion, or any other financial crime.
2. Scope
This Policy applies to all users of VESTEX, all services offered, and all VESTEX directors, officers, employees, contractors, and agents.
3. Know Your Customer (KYC)
- All users must complete identity verification before accessing deposit, withdrawal, trading, or card services.
- KYC includes verification of legal name, date of birth, nationality, residential address, and government-issued identification.
- Additional documentation (source of funds, proof of address, employment, corporate structure) may be required for higher-risk customers or higher transaction volumes.
- KYC is refreshed periodically and upon trigger events (risk changes, ID expiry, regulatory requirements).
4. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
VESTEX applies a risk-based approach. Customers are categorised as low, medium, or high risk based on factors including:
- Country of residence and citizenship
- Source of funds and wealth
- Occupation and industry
- Politically exposed person (PEP) status
- Expected and actual transaction patterns
- Products and services used
High-risk customers are subject to Enhanced Due Diligence, including additional documentation, senior management approval, and enhanced ongoing monitoring.
5. Sanctions Screening
VESTEX screens all users and transactions against international sanctions lists including, but not limited to, OFAC, UN, EU, UK HMT, and BVI sanctions. Users appearing on such lists will be denied service. Attempted transactions involving sanctioned jurisdictions or parties will be blocked and reported to authorities as required.
6. Transaction Monitoring
VESTEX monitors user activity for patterns indicative of money laundering, terrorist financing, fraud, or sanctions evasion. Suspicious activity is escalated to the Money Laundering Reporting Officer (MLRO) for investigation and potential reporting to competent authorities.
7. Suspicious Activity Reporting
VESTEX will report suspicious activity to the BVI Financial Investigation Agency (FIA) and other competent authorities as required by law. Users may not be notified that a report has been filed ("tipping off" prohibition).
8. Record Keeping
VESTEX retains KYC records, transaction records, and investigation files for at least five years after account closure or the last transaction, as required by applicable law.
9. Training
All VESTEX staff receive AML/CFT training relevant to their role, covering legal obligations, red flags, escalation procedures, and internal controls.
10. Independent Audit
VESTEX's AML/CFT program is subject to independent audit to verify effectiveness and regulatory compliance.
11. Prohibited Activities and High-Risk Customers
VESTEX does not provide services to:
- Individuals or entities on sanctions lists
- Residents of jurisdictions where the Service is prohibited
- Anonymous or unverified customers
- Entities that refuse to provide required KYC or source of funds documentation
- Activities involving darknet markets, mixing services used to obscure origin, ransomware payments, or other illicit finance
12. Governance
VESTEX maintains a Compliance Officer and MLRO, both approved by the relevant regulator, with direct access to senior management and the board. The Compliance Officer is responsible for the AML/CFT program and its effective implementation.
13. Contact
Questions about this Policy or to report suspicious activity (non-tipping-off basis): compliance@vestex.ai.