1. Purpose and Scope
The purpose of this policy is to establish the framework by which Worldchem Digital Market Ltd. (hereinafter “the Company”) prevents, detects, and reports attempts to use its digital marketplace, money transfer, and forex platforms for money laundering or terrorist financing.
This policy applies to all executives, employees, contractors, and third-party partners operating on behalf of the Company. The Company adheres strictly to the guidelines set forth by the Financial Action Task Force (FATF) and the regulatory authorities of the jurisdictions in which it operates.
2. Roles and Responsibilities
The Company will appoint a designated Anti-Money Laundering Compliance Officer (AMLCO).
The AMLCO is responsible for:
- Developing, implementing, and updating the AML/CTF program.
- Overseeing the daily compliance of the Know Your Customer (KYC) procedures.
- Reviewing internal escalations regarding suspicious activities.
- Filing Suspicious Activity Reports (SARs) with the relevant financial intelligence authorities.
- Ensuring all staff complete mandatory, annual AML training.
3. Customer Due Diligence (CDD) and KYC
Worldchem Digital Market Ltd. prohibits anonymous accounts and accounts under fictitious names. A risk-based approach will be applied to verify the identity of all users before granting access to financial transactions.
3.1 Individual Customers (Retail)
Before processing any transactions, the Company will collect and verify:
- Full legal name.
- Date of birth.
- Current residential address.
- A valid, unexpired government-issued photo ID (e.g., Passport, National ID).
- A live facial biometric scan or “selfie” to match against the provided ID.
3.2 Corporate Customers (Merchants & B2B)
For businesses registering on the platform, the Company will collect:
- Certificate of Incorporation or Business Registration.
- Memorandum and Articles of Association.
- Proof of registered business address.
- Identification documents for all directors and Ultimate Beneficial Owners (UBOs) holding 25% or more equity.
4. Enhanced Due Diligence (EDD)
Enhanced scrutiny will be applied to user accounts classified as “High Risk.”
4.1 Politically Exposed Persons (PEPs)
Any user identified as a PEP, or a close family member/associate of a PEP, is automatically classified as High Risk.
For these accounts, the Company must:
- Obtain Senior Management approval before establishing the business relationship.
- Take reasonable measures to establish the Source of Wealth and Source of Funds for the account.
- Subject the account to continuous, elevated transaction monitoring.
4.2 High-Risk Jurisdictions
Users operating from or sending funds to countries identified by FATF as having strategic AML deficiencies will be subject to EDD, including mandatory proof of the transaction's purpose.
5. Transaction Monitoring
Worldchem Digital Market Ltd. will utilize automated transaction monitoring systems to identify unusual patterns.
Red flag triggers include, but are not limited to:
- Structuring (Smurfing): Multiple transactions just below the reporting threshold within a short timeframe to avoid detection.
- Velocity: An abnormally high volume of transfers originating from a newly established account.
- Pass-Through Activity: Funds deposited into the digital wallet and immediately transferred out without economic purpose.
- Geographic Anomalies: Sudden transactions involving high-risk jurisdictions inconsistent with the user's profile.
When a system alert is triggered, the transaction will be temporarily frozen pending manual review by the compliance team.
6. Suspicious Activity Reporting (SAR)
If an employee or the automated system detects activity that provides reasonable grounds to suspect money laundering or terrorist financing:
- The activity must be escalated immediately to the AMLCO.
- The AMLCO will review the transaction history and KYC profile.
- If suspicion remains, the AMLCO will file a SAR with the national Financial Intelligence Authority within the legally mandated timeframe.
- Tipping Off: It is strictly prohibited, and a criminal offense, for any employee to inform the user that their account is under investigation or that a SAR has been filed.
7. Record Keeping
To ensure a complete audit trail for regulatory bodies and law enforcement, Worldchem Digital Market Ltd. will retain the following records for a minimum of five (5) years after the termination of the business relationship or the date of the last transaction:
- All KYC and identity verification documents.
- Comprehensive transaction histories, including sender, receiver, and timestamps.
- Internal compliance reviews, investigation notes, and copies of filed SARs.
All data will be stored securely in compliance with applicable data protection and privacy laws. See our Data Retention & Destruction Policy for full detail.
8. Employee Training
All employees whose duties involve financial processing, customer support, or technical infrastructure will undergo AML/CTF training within 30 days of hiring and annually thereafter.
Training will cover:
- The legal definition of money laundering and terrorist financing.
- How to recognize red flags and suspicious behaviors.
- The internal procedure for escalating suspicious activities.
- The severe legal and internal consequences of failing to comply with this policy.