Anti-Money Laundering, Anti-Terrorist Financing Statement

1. Company Policy Statement

Kakeni.com is not a financial institution and is accordingly not directly subject to statutes applicable to financial institutions. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (“AML/CFT”), Kakeni.com expressly prohibits the use of its products for any illicit activity.

Kakeni.com follows global best practices, including:

  • Adoption of a written AML policy and procedures.
  • Designation of a compliance officer to oversee implementation.
  • Provision of AML training to personnel.
  • Independent reviews and monitoring of AML controls.

2. Definitions

  • Money Laundering: The process of making illegally-gained proceeds appear legal, involving placement, layering, and integration.
  • Suspicious Activity: Transactions that indicate potential fraud or illegal purposes.
  • Sanctions: Measures to restrict activities of targeted individuals or countries for security or anti-terrorism purposes.

3. Governance and Oversight

Kakeni.com has appointed a Chief Compliance Officer (CCO) responsible for coordinating AML policy implementation, developing AML initiatives, and investigating suspicious activities. Regular AML training is provided to employees.

4. Know Your Customer (KYC) and Transaction Monitoring

Customer Due Diligence

Kakeni.com adopts risk-based customer due diligence (CDD) procedures to understand the purpose of user relationships. Key measures include:

  • Collecting baseline information (e.g., wallet address, email).
  • Verifying user identity and age via third-party providers.
  • Ensuring compliance with sanctions lists and prohibitions.

Enhanced Due Diligence

Users triggering red flags undergo enhanced KYC checks, including:

  • Full legal name and address.
  • Country of citizenship.
  • Government-issued identification document.
  • Source of funds and wealth verification.

Geo-Blocking

Kakeni.com implements geo-blocking to restrict access from prohibited or sanctioned jurisdictions.

5. Transactions Monitoring

Kakeni.com conducts real-time transaction monitoring to identify unusual activity. Key components include:

  • Identifying unusual activity via rule-based systems.
  • Screening for sanctioned parties using third-party tools (e.g., Chainalysis).
  • Prohibiting transactions involving high-risk or anonymous wallets.
  • Monitoring for anti-mixing measures to detect suspicious patterns.

6. Education and Training

Kakeni.com, under the oversight of the CCO, provides AML, anti-terrorist financing, and trade sanctions compliance training to its employees on a periodic basis.

7. Reporting

Kakeni.com is obligated to report suspicious activities to relevant regulators, including activities involving sanctions, money laundering, or terrorism financing.