Money Laundering – Coinstec

Anti-Fraud - Money Laundering

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COINSTEC™'s Operational Anti-Fraud Department, in particular, the Anti-Fraud Commissioner, is the first line of detection, investigation and protection in preventing Prohibited Conduct through the Users and transactions appraisal process.

The Anti-Fraud Commissioner will be responsible for the proper fulfillment of the Anti-Fraud Policy.

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(a) Authority

The Anti-Fraud Commissioner, through the Operational Anti-Fraud Department, working in close collaboration with the Nominated Officer (cf. Know-Your-Customer Policy), shall be responsible for:

- receiving reports of alleged or suspected Prohibited Conduct involving COINSTEC™, its Users and/or related transactions;

- investigating such matters and cooperating directly with the Nominated Officer in order to facilitate the investigations;

- reporting its findings to the COINSTEC™ management and relevant authorities, as well as any other third party on a need-to-know basis.

For situations requiring an urgent response, the Anti-Fraud Commissioner may take any necessary measures required for the investigation, notably to preserve evidence.

(b) Independence

The Operational Anti-Fraud Department shall enjoy complete independence in the exercise of its responsibilities. The Anti-Fraud Commissioner shall have full authority to open, pursue, close and report on any investigation on Prohibited Conduct within its remit without prior notice to, the consent of, or interference from any other person or entity.

(c) Professional Standards

All Prohibited Conduct investigations conducted by the Operational Anti-Fraud Department shall be fair and impartial, with due regard to the rights of the Users and persons or entities involved. The presumption of innocence applies to those alleged to have engaged in misconduct. Those involved in the Prohibited Conduct investigation (be those under investigation or those conducting the investigation) should be aware of their rights and obligations and ensure they are fully respected.

(d) Cooperation

All Users are required to cooperate with the Operational Anti-Fraud Department and the Anti-Fraud Commissioner promptly, fully, efficiently and in the manner specified by the Operational Anti-Fraud Department, including by answering relevant questions and complying with requests for information and records.

(e) Confidentiality

In accordance with COINSTEC™ internal rules on access to information, all information and documents collected and generated during a Prohibited Conduct investigation, not already in the public domain, shall be kept strictly confidential. The confidentiality of the information collected will be respected both in the interests of those concerned and the integrity of the investigation.

In particular, during the Prohibited Conduct investigation the confidentiality will be respected in so far as it would not be contrary to the interests of the investigation.

The Operational Anti-Fraud Department shall disclose such information and documents only to those persons or entities authorized to receive them or otherwise on a need-to-know basis.