8. AML/CFT and Know-Your-Client (KYC) Policy
Know Your Client (KYC) Policy: XREX conducts ongoing verification of individuals and organizations using the Services. You agree to provide complete and accurate personal information (including but not limited to your name, email address, registered address, gender, phone number, nationality, date of birth, tax identification number or ID card number or passport number, a bank account registered in your name, and other registration and transaction-related information) that XREX and any appointed third-party service providers including financial institutions and KYC/AML compliance vendors may from time to time request.
These third parties may collect, process, or use your personal information for the purposes of performing their designated tasks, which may include verifying the authenticity of your bank account, ensuring compliance with Applicable Laws, and fulfilling AML/CFT obligations. Based on the outcomes of such verifications, XREX and its appointed third parties reserve the right to take any measures they deem appropriate. In providing us with your information, you confirm that (a) the accuracy, authenticity and completeness of all such information, documents and materials and (b) you have not withheld any information, document or material that may influence our evaluation of you for the purposes of registering or maintain your XREX Account or providing Services to you.
You represent that you are not, directly or indirectly involved in any activity that may contravene the Applicable Laws, in particular the AML/CFT laws and regulations.
You further represent and warrant that, to the best of your knowledge:
you;
any person controlling or controlled by you;
if you are a privately held entity, any person having a beneficial interest in you; and
any person for whom you act as agent or nominee in connection with this trading,
are not listed on any sanctions of restricted party list issued by the relevant regulatory authority in Singapore or any other applicable jurisdiction. Please be advised that XREX may not accept any trading activities from a prospective user if it cannot make the representations set forth in Paragraphs 8.3 and 8.4 above. In addition, if you cannot make these representations, XREX, at its sole and absolute discretion, may prohibit, terminate or suspend your trading activities and account.
You agree to promptly notify XREX if you become aware of any change in the information provided in Paragraphs 8.3 and 8.4 above. Under the Applicable Laws, XREX may be required to “freeze” your account, including suspending trading activities in order to comply with the regulatory obligations. XREX and/or its representatives may also be required to report such action and to disclose your identity to the relevant authorities. In particular, you agree that XREX shall be entitled to (i) exercise its rights under Paragraphs 1 and 3 of the Terms; and (ii) report instances of fraudulent, criminal, suspicious activity or transactions to the relevant authorities.
You agree to promptly provide any additional documentation XREX and/or its representatives may request, as deemed necessary by XREX to comply with Applicable Laws. You acknowledge and consent to the disclosure of such information by XREX and/or its representatives to the regulatory authorities in Singapore or other jurisdictions, particularly in connection with AML/CFT requirements. You further agree to have face-to-face meetings with representatives of XREX or take any other action as XREX may require for purposes of performing enhanced due diligence on you so that XREX may establish your source of wealth and source of funds for any transactions carried out in the course of your use of the Services.
You agree that XREX and/or its representatives may disclose your information to one another, to any service provider engaged by XREX, or to any regulatory body in any applicable jurisdiction. Such disclosure shall not be deemed a breach of any legal or contractual restriction on the disclosure of information.
AML/CFT Policy: XREX constantly monitors transactions conducted on the Site and through its Services. We may suspend or block any transaction without prior notice to you if we have reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws, or that the transaction presents risks related to money-laundering, terrorism financing, or similar unlawful activities. In compliance with Applicable Laws, XREX will report any suspicious activity or transaction to the relevant authorities. XREX reserves the right to deny or suspend access to the Services to anyone:
refusing or unable to provide sufficient evidence of their identity and/or their source of funds to the satisfaction of XREX;
providing information which XREX determines to be false, misleading, or otherwise unacceptable in any respect; or
is identified as a designated individual or entity as defined or set out in the Singapore Sanctions Laws.
Disputes: If XREX has reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws or any Applicable Laws, or that any DPTs in your XREX E-Wallet are stolen, unlawfully possessed, or represent the proceeds of any illegal activity, we may, in our sole discretion, place an administrative hold on the affected DPTs. This hold will remain in place until the dispute is resolved and you provide evidence acceptable to XREX. XREX will not participate in or mediate the resolution of such disputes. You acknowledge and agree that XREX shall not be liable for any Losses arising from such a hold, or from your inability to withdraw DPTs or Fiat Money, or to execute transactions during the hold period.
You are responsible for ensuring that your email address and mobile phone number on file with us remain current and valid to receive electronic Communications. If we send you an electronic Communication and you do not receive due to outdated or incorrect contact information, the blocking by your service provider, or other delivery issues, the Communication shall nonetheless be deemed to have been provided to you. You can update your contact details at any time by filing a support request at [email protected] or informing your designated relationship manager in writing. If your contact details become invalid and the Communications sent to you are returned, we may deem your account inactive, and you may be unable to complete any transaction via our Services until valid and accurate contact information is provided.
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