AML & CTF Policy

The programme is owned by our Money Laundering Reporting Officer (MLRO) and overseen by the Board's Risk & Compliance Committee. It is reviewed annually by an independent external auditor.

Every customer undergoes identity verification, sanctions/PEP screening, jurisdictional risk scoring and adverse-media checks before transacting.

Triggered by PEP status, high-risk jurisdictions, unusual transaction patterns, or large volumes. Includes senior-management sign-off, source-of-funds/wealth evidence and ongoing enhanced monitoring.

All deposits, withdrawals and trades are monitored in real time using on-chain analytics (Chainalysis, TRM Labs, Elliptic) and behavioural rules. Suspicious activity is escalated to the MLRO within 24 hours.

For transfers above the FATF threshold, GXT Exchange shares originator and beneficiary information with counterparty VASPs through the Sumsub Travel Rule network and IVMS-101 messaging.

We screen against OFAC, UN, EU, UK HMT, OFSI, MAS and other applicable sanctions lists. Hits result in immediate blocking, account freeze and regulatory reporting.

Suspicious activity is reported to the relevant Financial Intelligence Unit (FIU) within legally mandated timelines. Tipping off is strictly prohibited.

All KYC documents, transaction records and suspicious activity reports are retained for a minimum of 5 years.

All employees complete AML/CTF training annually. Compliance, customer-support and engineering teams receive role-specific training.

Report suspected violations confidentially to mlro@gxtexchange.com.