The INX Digital Company, Inc and its wholly-owned, separately operated subsidiaries have developed a Bank Secrecy Act and Anti-Money Laundering Compliance Plan (“BSA/AML Plan”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States and other countries where we conduct business.
The elements of our plan include, but are not limited to, the following:
Our BSA/AML Compliance Plan has been reviewed and approved by our Managers. Our BSA/AML Compliance Plan is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. We are regulated by the US state departments of financial institutions identified in the “Licenses” section of this webpage and our BSA/AML Compliance Plan is subject to their review and approval.
We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.
Our employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months, and all new employees receive training, to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. All documentation related to compliance training including materials and attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.
Our CCO is responsible for developing and enforcing the policies and procedures of our BSA/AML Compliance Plan. Our CCO is required to report any violations of our BSA/AML Compliance Plan directly to our CEO and our Managers. In addition, our CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Compliance Plan audit at least annually.
Our Customer Identification Program (“CIP”) is an important part of our BSA/AML Compliance Plan, and helps us detect suspicious activity in a timely manner and prevent fraud.
In order to open an account and use the platform, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use our platform.
To verify the identity of individuals, we must receive, for each person:
Additionally, in order to verify the information provided, we must receive the following documentation for each person
Prior to opening an account for an entity or institutional customer, we attempt to collect, verify, and authenticate the following information:
While Authorized Signers have full authority, an Authorized Trader can perform trades (purchases & redemptions) and obtain account information; any changes to the account (changes to wiring instructions, address, Authorized Signers & Traders, etc.) can only be made by an Authorized Signer.
Institutional accounts must provide INX Digital with a completed Certification of Beneficial Owners. This form must be completed by the person opening an account with INX Digital on behalf of a legal entity.
For the purposes of this form, a legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public document with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or a foreign country.
This form requires institutional accounts to provide the name, main residential address, date of birth and Social Security number (SSN for US persons or passport number or other similar information, in the case of non-U.S. persons) for the following individuals (i.e., the beneficial owners):
To verify an institutional account, INX Digital must receive the following documentation:
It’s important to note that entity documentation may vary significantly depending on the country of incorporation. If your institution successfully meets and completes our CIP requirements, we will complete your account onboarding.
Over the course of your customer experience on the platform, our team may reach out to you for additional information in order to ensure the safety and integrity of our customer base and our trading platform, and as required for ongoing compliance with our regulatory obligations. Please be aware that your failure to comply with these requests may result in restrictions on your account.
We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on our platform. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our BSA/AML Compliance Officer reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.
In addition, all currency transactions over a determined USD value are reported to FinCEN via a CTR filing.
Our BSA/AML Compliance Officer maintains records and supporting documentation of all SARs and CTRs that have been filed.
All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.
The BSA/AML Compliance Officer is responsible for overseeing our BSA/AML Compliance Plan and presenting findings to our CEO and Managers.
Our BSA/AML Compliance Officer oversees the performance of an independent test of our BSA/AML Compliance Plan at least annually. Results are shared with the Managers.