Syarat & Ketentuan

AML Policy

Anti-Money Laundering (AML) Policy

Pointex LLC

 

1. Introduction

Money laundering is the act of disguising the origins of illicitly obtained funds—such as those from fraud, drug trafficking, or other criminal activities—by converting them into seemingly legitimate assets. This process is prohibited under national and international law.

Pointex LLC is fully committed to combating money laundering and terrorist financing and maintains strict policies and procedures in line with global and local AML regulations, particularly those relevant to digital finance and crypto assets.

 

2. AML Program Overview

To prevent and detect money laundering or terrorist financing, Pointex LLC has implemented a comprehensive AML framework that includes the following measures:

 

2.1 Customer Identification and Verification (KYC)

    • All users must complete the Know Your Customer (KYC) process before gaining full access to services.

    • Pointex LLC uses Sumsub, a third-party KYC provider, to verify identity documents (e.g., passport, government-issued ID, driver’s license) and perform liveness checks (facial recognition) to ensure the authenticity of the applicant.

    • Customers are also required to submit Proof of Address (POA) documents, such as utility bills or bank statements issued within the last 3 months.

    • Enhanced due diligence (EDD) applies to high-risk individuals, including politically exposed persons (PEPs).

 

2.2 Crypto Asset Monitoring

    • To mitigate the risk of crypto asset misuse, Pointex LLC deploys advanced blockchain analytics tools to monitor wallet addresses, transaction flows, and sources of funds.

    • A robust Transaction Monitoring System (TMS) detects suspicious activities, such as irregular or large transfers involving crypto assets.

2.3 Transaction Limits and Restrictions

    • Transaction thresholds are defined according to user risk profiles and applicable regulatory guidelines.

    • Third-party transactions are prohibited. All deposits and withdrawals must be conducted using accounts or wallets registered in the verified user's name.

    • Crypto asset withdrawals are only permitted to verifiedy wallet addresses provided during registration.

2.4 Suspicious Activity Reporting (SAR)

    • Any transactions or behavior indicative of money laundering, terrorist financing, or fraud are subject to internal review and may be reported to relevant authorities under SAR protocols.

    • Common red flags include use of obfuscation tools, structuring of transactions, or rapid transfers across accounts.

2.5 Prohibition of Cash Transactions

    • Pointex LLC does not accept or process any cash transactions. All funds must be transferred through verifiable digital means to ensure transparency and auditability.

2.6 Suspension and Freezing of Accounts

    • Pointex LLC reserves the right to freeze, suspend, or terminate user accounts if suspicious activities are detected or if customers fail to comply with AML requirements.

2.7 Record Keeping

    • Customer identity records, transaction data, and compliance documents (including SARs) are securely retained for a minimum of five (5) years in accordance with legal obligations.

 

3. Customer Identification Requirements

  • Identity Verification: Government-issued photo ID (e.g., passport, national ID, driver’s license).

  • Facial Recognition: Liveness check via Sumsub.

  • Proof of Address: Recent utility bill, bank statement, or equivalent (within 3 months).

4. Deposit and Withdrawal Policies

  • The sender's name (for deposits) and the recipient's name (for withdrawals) must match the verified user information.

  • No third-party deposits or withdrawals are permitted.

  • Crypto asset withdrawals must only be made to pre-approved and verified wallet addresses.

5. Crypto Asset-Specific Measures

  • All crypto deposits and withdrawals must comply with AML regulations and must originate from or be sent to verified wallet addresses.

  • Transactions involving mixers, anonymization services, or obfuscation patterns will be flagged and potentially blocked.

  • Transfers showing abnormal behavior are subject to further compliance review.