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AML and KYC Policies

POLICY FOR THE MANAGEMENT OF RISK OF MONEY LAUNDERING, TERRORIST FINANCING AND THE FINANCING OF PROLIFERATION OF WEAPONS OF MASS DESTRUCTION


PANDA EXCHANGE (hereafter PANDA ) has established as policy for the management of risk of Money Laundering, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction (ML/TF/WMD) a number of measures and procedures in order to prevent this entity to be used, directly or indirectly, for illegal activities.

This policy is implemented by the Guidebook SARLAFT (System of Management of Risk of ML/FT/WMD by its acronym in Spanish), which states that PANDA must identify and verify the identity of every user and counterparties, know the affiliated benefit and perform a transaction monitoring of virtual assets (cryptocurrency) or local currency (fiat) transacted, in order to detect operations or activities with unusual behavior. As a result of this process, PANDA will perform a risk management and eventually it will inform the UIAF (Entity for Financial information and Analysis by its acronym in Spanish) the operations labeled as suspicious.

The “Due Diligence” is the main element for the development of the policy and the procedures established for protecting the interests, business, contracts and operations of PANDA with its associates. Under no circumstances, measures of simplified due diligence will be applied.

PANDA has established protocols intended to know their users and counterparties through the collecting, verification and registry of information updated regularly.

PANDA will not make exceptions for any Politically Exposed Person, who will undergo a more comprehensive due diligence. Moreover, PANDA will inquire about the origin of funds used to trade with virtual assets (cryptocurrency) or local currency (fiat) as an essential part of the Management of risk of ML/TF/WMD. In addition, PANDA will apply an enhanced due diligence to operations or bonds with more risky jurisdictions –according to FAFT guidelines– and counterparties considered as high risk.

Although in accordance with the Superintendencia de Sociedades, PANDA is required to implement SAGRILAFT, the entity has decided voluntarily to implement SARLAFT according to the guidelines stated by the Superintendencia Financiera de Colombia.

Finally, PANDA has designated a Compliance Officer, main and deputy, who will have human, logistic, financial and technological resources in order to give effect to this policy, as well as, to monitor the effective, efficient and appropriate operation of SARLAFT.

Legal Representative

-Panda Exchange-