Quedex Bitcoin Derivatives Exchange operates as a Bitcoin-only trading platform, which means that some of the risks associated with the exchange of virtual currencies ("VC") for fiat money are not present at Quedex.
As indicated in FATF Guidance For Risk-Based Approach To Virtual Currencies (2015), "AML/CFT controls should target convertible VC nodes—i.e., points of intersection that provide gateways to the regulated financial system—and not seek to regulate users who obtain VC to purchase goods or services.". Due to the architecture of the Quedex platform and products traded within it, Quedex is not considered a gateway to the regulated financial system. Nevertheless, Quedex is committed to providing safe, compliant and reputable Services and to countering any potential occurrences of such ML/CF risks and hence implements certain AML/CTF policies as summarised below.
Quedex’s AML policy is designed to prevent money laundering and terrorist financing. It is implemented in accordance with Gibraltar laws and regulations, including the Gibraltar Proceeds of Crime Act (2015), and furthermore, it takes into close consideration the FATF Guidance For Risk-Based Approach To Virtual Currencies (2015) and guidance issued more generally by Gibraltar Financial Services Commission. Its aim are to set in place standards and procedures that are commensurate with the perceived risks the Platform itself, and Quedex more widely, may be exposed to.
- Quedex follows a Risk-Based Approach in the process of assessment and managing of any money laundering and terrorist financing risks that may arise within the Platform and in relation to any proposed or current Members.
- All activities within the platform are monitored, and whenever it is deemed appropriate, Quedex will report any suspicious activities internally and, if considered necessary, escalate these reports to the relevant authorities.
- At any time, Quedex may ask Members to submit additional data and may request verification of submitted data, including documentary proof.
- Quedex may apply enhanced due diligence for those Members who in Quedex’s sole discretion Quedex believes may present a higher risk, as well as for Members that are Politically Exposed Persons as defined by FATF.
- Records of orders, transactions, deposits, withdrawals and other activities within the Platform will be maintained for sufficient periods.
- Quedex’s staff members are adequately trained and aware of all necessary AML/CTF procedures and any updates to the same.
- Individuals whose names appear on prescribed sanctions lists are prohibited from opening an Account with Quedex and will be denied Membership. Quedex will screen against sanctions lists for all jurisdictions in which it operates, including the United Kingdom and European Union.
- Quedex may deny, suspend or terminate Membership to any individual or legal entity without disclosing reason for the denial or cancellation of Membership, in particular due to lack of compliance with verification requests, appearance on sanctions lists or suspicious activity.
- Quedex may use geolocation services or Blockchain analysis tools in the process of evaluation of a Membership application, activity monitoring or crediting a Member's Account with a deposit sent to addresses belonging to Quedex.
Last updated: 26 Mar 2018