Anti-Money Laundering Policy

Coinciding with the launch of Leondrino Wallet, Leondrino Exchange would like to inform its clients about the implementation of measures according to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (hereinafter AML/CFT Act). In order to support government in the fight against financing of terrorism and money laundering, the Act requires all financial institutions and related service providers to collect, verify and store identity data of persons and entities seeking to establish an account or Leondrino Wallet. Correspondingly, based on risk assessment, Leondrino Exchange has developed an internal Anti-Money Laundering Program and Counter Terrorism Financing Program (hereinafter AML Program to be aligned with the goals of the AML/CFT Act. These include:

  • to detect and deter Anti-Money Laundering and Counter Terrorism Financing ;
  • to maintain and promote the reputation of the financial system by implementing the recommendations of the Financial Action Task Force (FATF), where appropriate in the context; and
  • to contribute to public confidence in the financial system.

By signing up for a Leondrino Trading Account (Leondrino Wallet including trading entitlements), you accept the following terms and conditions:

  • You warrant that you comply with all applicable laws and regulations to combat money laundering, including, but not limited to the AML / CTF Act and the associated, currently effective rules and regulations;
  • You have no knowledge of and no reason to suspect that:
    • the money used to finance the deposit on your account was originated or will be originated and thus was connected and will be connected with money laundering or other activities regarded as illegal within the framework of applicable laws and regulations or other as prohibited activities under an international convention or agreement (“illegal activities”)
    • the proceeds out of your investment in the depot will be used to finance illegal activities; and
  • You agree to immediately provide us with all the information that we need to adhere to all applicable laws and regulations to combat money laundering.

In accordance with the AML Program, Leondrino Exchange will, upon the account opening and on an ongoing basis, exercise due care in accordance with each client’s risk levels.
This means: in accordance with the Privacy Act of 1988, Leondrino Exchange will request a specified set of background information to confirm a client’s identity; store this identity-related information as well as methods and results of the identity check; inform clients that we will request information and reconcile with government-provided lists of terror suspects.
The requested information shall include:

  • the full name of the customer; and
  • the date of birth if it is a natural person; and
  • if the person who opened the account is not the customer himself, the relationship of the person with the customer; and
  • the address or registered office of the customer; and
  • the company name or the customer’s registration number;
  • the expected level and the type of activity to be undertaken;
  • the expected source of funds, which are intended to be used in the business relationship; and
  • details about employment and assets or sources of income.

To verify the above information, Leondrino Exchange will request the following documentation from prospective clients:

For private individuals:

  • passport or identity card or similar document that:
    • includes name, date of birth and a photograph of the person to whom the document is issued, and
    • is issued by a national government, the United Nations or an agency of the United Nations.

For corporate clients

  • copy of the certificate of incorporation or equivalent national document;
  • copy of the bylaws or equivalent national document;
  • certificate of good standing or other proof of the registered business address of the company;
  • a copy of the consent of board to open an account and to give corresponding authorization to the account-holding person;
  • proof of identity of the directors, in the event that he / she makes contact with Leondrino Exchange on behalf of customers (according to the above provisions to ensure the identification of individuals).

Leondrino Exchange might request additional documentation and background information. In some instances, copies of requested documents may suffice, provided they have been officially certified and appraised.

Ban of Sham Tansactions
We hereby inform customers of Leondrino Exchange regarding prohibited transactions, which are commonly called “sham transactions”. This prohibition is imposed according to the AML / CFT Act in order to identify, to defuse and manage potential risks in relation to money laundering and terrorist financing for Leondrino Exchange.
This provision requires that all orders are made in good faith for the purpose of access to and making profits from movements of quotas in financial instruments. No Customer may open up directly or indirectly opposite positions (ie buy and sell orders) in the same financial instrument, where the intention of the customer does not lie in the fact to make profit from speculative activities, but to avoid an honest, the market risk exposed market position.
It is also inadmissible, to open opposite positions in the same financial instrument for various eWallets or Leondrino trading accounts with shared beneficial ownership (this excludes accounts with less than 100% public ownership a) as well as eWallets or Leondrino trading accounts of customers who stand in any relationship to one another, if this is the intention of avoiding market risk or price competition. Such activities are also considered a violation of the sham transaction ban. The fact that there is a delay between the opening of opposite positions, does not exempt from this ban, if the performance entails a sham transaction result. The mere delay of opening a buy and sell order does not exclude, depending on the terms of the order, that orders are entirely or partially traded against each other. To the extent as orders are traded against each other, their outcome can be regarded as an illegal sham transaction, regardless of the fact that the orders were opened at different times.
In all cases where one of the above transactions is recognized, Leondrino Exchange may exercise its rights pursuant to the relevant User Agreement, which the user has explicitly agreed to as part of the account opening; including, but not limited to: cancellation or adjustment of the respective transactions of users.