AML/CTF Policy

Policy scope

This public summary applies to Trillion Capital Markets Inc. and Trillion Capital Markets AG in connection with their respective services. It describes the approach to financial-crime prevention; it is not an internal procedures manual, a guarantee of detection, or an expansion of either entity’s permissions.

Inc. is subject to applicable U.S. BSA/AML and sanctions requirements. AG is subject to the Swiss Anti-Money Laundering Act and applicable VQF SRO rules. Requirements for due diligence, reporting, retention, and restrictions depend on the entity and activity. SRO membership concerns AML supervision, not a banking or securities firm licence.

Policy summary

Trillion Digital is committed to conducting its business in accordance with all applicable laws and regulations, and in a way that enhances its reputation in the market. This policy records Trillion Digital's approach to the identification, mitigation and management of the risk that Trillion Digital's products and services might be involved in the facilitation of money laundering or the financing of terrorism.

Description of money laundering and terrorism financing

Trillion Digital defines money laundering ("ML") as activity which is designed to conceal or disguise the true origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate sources.

Terrorist Financing ("TF") is considered to be the act of providing financial support to terrorism or terrorist organisations to enable them to carry out acts of terrorism.

Objectives of Trillion Digital's AML/CTF policy

Trillion Digital has established an AML/CTF policy which sets the core principles for the management of ML/TF risk. Group standards support the separate obligations of each entity. Local requirements take precedence where they impose additional or different duties. The Policy is subject to regular review to ensure it remains current with regulator expectations and industry standards.

The core principles

Trillion Digital has adopted the following core principles:

• Trillion Digital opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.
• Suspicious matters are assessed and, where the applicable reporting conditions are met, reported to the competent authority. U.S. reporting and Swiss reporting to MROS follow their respective requirements. Confidentiality and prohibitions on tipping off apply.
• Trillion Digital will comply with the AML/CTF laws, rules and regulations of the countries that relate to AML/CTF where Trillion Digital has permanent places of business through which Trillion Digital provides services.
• Trillion Digital will endeavor to provide its products and services only for legitimate purposes to customers whose identities Trillion Digital has been able to reasonably ascertain.
• Trillion Digital will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by Trillion Digital's AML/CTF Program.
• Trillion Digital's employees are required to attend AML/CTF training to understand their obligations under the relevant laws, rules and regulations.
• Trillion Digital will monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent.
• Trillion Digital will manage new and revised changes to Trillion Digital's products, business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.

Know your customer ("KYC")

Trillion Digital applies due-diligence procedures required for the relevant entity, service, and risk. Applicable KYC policies and procedures to establish and verify the identity and bona fides of customers will also be complied with.

These will include:

• Customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk to Trillion Digital and require a higher level of due diligence;
• Procedures to establish if customers are known or suspected money launderers, terrorists or otherwise engaged in criminal activity (e.g. reviewing customers against government/United Nations/regulators' lists of proscribed persons);
• Enhanced Due Diligence undertaken where a transaction or a counterparty results in a heightened level of financial crime or reputational risk;
• A risk-based periodic review of existing customer records to maintain currency and completeness;
• Identification of contracting parties, authorised representatives, and beneficial owners, with additional source-of-funds or source-of-wealth checks where required;
• Ongoing monitoring of relationships and transactions using a risk-based approach, including relevant sanctions and politically exposed person checks;
• Required originator, beneficiary, and wallet-control information for transfers, including the applicable Swiss rules for blockchain transactions;
• Procedures prohibiting accounts/relationships with shell banks^[1];
• A clear statement on what records must be kept on customer identification and individual transactions and their retention period; and
• Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.

Suspicious activity

Trillion Digital staff are trained and made aware of "red flags", or anything that is unusual or out of the ordinary when dealing with customers and customer related information. Trillion Digital has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are escalated to the responsible compliance function for assessment and any required report or action. A customer may be asked for further information. Transactions or relationships may be restricted where legally required; reporting, freezing, and termination rules determine what action is permitted. We may be prohibited from explaining a report or restriction, and do not automatically notify other counterparties.

Trillion Digital's AML/CTF training program

Trillion Digital has a robust AML/CTF Training Program to educate employees in implementing and maintaining Trillion Digital's AML/CTF Program. All employees undergo initial AML/CTF training when they join Trillion Digital. In addition, there are ongoing training requirements for all employees.

Trillion Digital's record retention

Records are retained according to the applicable entity, record category, statutory period, and legal trigger. Swiss AML documentation is generally retained for ten years after the end of the business relationship or completion of the transaction, as applicable. Relevant U.S. BSA recordkeeping rules generally require at least five years, with the starting point depending on the record. Legal holds or other obligations may require longer retention. These periods do not apply to every website enquiry or analytics record.

Independent review of the AML/CTF program

Trillion Digital's AML/CTF Program is subject to independent review in accordance with the requirements of each local jurisdiction. The results of the review are presented to senior management for review and action. In addition, regular reporting is provided by Compliance to Trillion Digital's Board.

For how personal information is handled and how to contact us, read our Privacy Policy. Report concerns to compliance@trilliondigital.io.