KYC Process
Before a user can make cryptocurrency purchases using fiat currency, Coinstradehub will conduct a thorough identity verification process tailored to the user’s country of residence. This process will involve the following steps:

• User Identification and Verification: Coinstradehub will verify the user’s identity through documents, data, or other reliable and independent sources to ensure full identification.
• Sanctioned Individuals Check: The user’s details will be checked to confirm they are not a sanctioned individual or operating from a sanctioned country.
• PEP Status Verification: Coinstradehub will verify whether the user is a Politically Exposed Person (PEP) to assess potential risk.
• Adverse Media Check: Coinstradehub will assess whether the user has been featured in any adverse media reports that would classify them as a high-risk individual.

To perform these checks, Coinstradehub will utilize Sumsub for the collection of user KYC data and ComplyAdvantage for screening PEP status, sanctions lists, and adverse media reports.

Anonymous Users
Upon initial account creation on the Coinstradehub platform, users will remain anonymous. These users will register using a verified email address, with verification completed through a one-time code sent to the provided email. To secure the account, users will be required to set a password.

Anonymous accounts will face the following restrictions:

• They will not be able to buy or sell cryptocurrency using fiat.
• Cryptocurrency transaction values will be capped at a limited threshold.

Any attempt to exceed these transaction limits or engage in fiat-crypto trading will automatically trigger the Know Your Customer (KYC) process.

Coinstradehub reserves the right to screen any user at its discretion prior to authorizing any transactions and will continue to perform ongoing screening throughout the user’s engagement with the platform.

Coinstradehub KYT (Know Your Transaction) Screening Policy for Cryptocurrency Deposits all cryptocurrency deposits made to Coinstradehub will undergo Know Your Transaction (KYT) screening to ensure compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations.

KYT is designed to assess the risk of each transaction, including identifying funds from high-risk or illicit sources. The Chainalysis platform will be used for all cryptocurrency transaction monitoring.

Chainalysis analyzes the blockchain to detect any risks associated with the source of the funds. As blockchain gives us no ability to block incoming transactions from any source the system is unable to stop the arrival of funds from flagged sources – however any funds from flagged sources will be frozen along with the associated account until the flags have been investigated by the compliance team.

Chainalysis KYT (Know Your Transaction) – Compliance Software Suite

With the increasing adoption of cryptocurrencies, businesses without proper controls risk regulatory penalties, reputational harm, and potential exclusion from the financial system. To mitigate these risks, companies need an automated solution to assess money laundering risks and comply with regulatory standards, while maintaining key stakeholder relationships.
Chainalysis KYT offers a comprehensive cryptocurrency transaction monitoring solution tailored to meet these needs. Designed with anti-money laundering (AML) compliance workflows in mind, its intuitive interface streamlines the process of detecting and managing high-risk transactions.

• Real-Time Transaction Screening: Through the KYT API, Coinstradehub can monitor large volumes of activity in real-time, continuously identifying high-risk transactions. Periodic reviews of the user base ensure the latest data is incorporated.
• Case Management: KYT enables users to open and close case reviews for specific users, maintaining detailed records of decisions. All information can be exported for AML reporting purposes.
• Enhanced Due Diligence: For individual users, KYT provides detailed transaction tracing through integration with Chainalysis Reactor, allowing compliance teams to investigate the flow of funds.

All flagged transactions, as well as a sample of routine transactions, will be reviewed. Funds from flagged accounts will be automatically frozen until cleared by the Compliance team. Transactions that fail to pass compliance checks will trigger a Suspicious Activity Report (SAR).

KYT performs ranked analyses of wallet relationships, assessing their connection to known addresses and their associated risk levels. This allows monitoring of all user activity, both on and off the platform.

Outgoing transactions are also monitored to prevent users from sending cryptocurrency to fraudulent or flagged addresses. Similar to inbound transactions, any flagged outbound transactions will be blocked until cleared.

Any frozen assets will only be released following a thorough review by the Compliance team, using Chainalysis Reactor to investigate the underlying reason for the flag. The Compliance team has full authority to either file a SAR or unfreeze assets based on their findings.

Continuous Monitoring
Coinstradehub employs automated monitoring systems to ensure the ongoing compliance and integrity of user accounts. These systems actively check for changes in a user’s status, including but not limited to:

• Verification that identity documents are up-to-date and valid.
• Ensuring proof of address remains current and valid.
• Monitoring for any new Politically Exposed Person (PEP) status, sanctions hits, or adverse media reports that may affect the user.

Should any changes be detected, the system will trigger an appropriate action based on the severity of the issue. In serious cases, the user may be immediately blocked from accessing their account, pending a thorough review by the Compliance team.

Coinstradehub also undertakes continuous monitoring of user transactions to ensure compliance with enhanced due diligence (EDD) requirements, particularly regarding the source of funds. This involves analyzing blockchain activity using Chainalysis, which rates cryptocurrency wallets based on their proximity to and interaction with blacklisted wallets published by U.S. and European authorities.

As part of Coinstradehub’s second line of defence, the Money Laundering Reporting Officer (MLRO) will conduct regular checks to ensure that the continuous monitoring process is functioning effectively. The MLRO is responsible for ensuring that irregular or suspicious activities are identified and appropriately escalated for further investigation.

Money Laundering Reporting Officer (MLRO)
Coinstradehub has a Money Laundering Reporting Officer (MLRO), who is duly authorized to oversee and enforce the AML/KYC policy. The MLRO is responsible for supervising all aspects of the company’s anti-money laundering and counter-terrorist financing efforts. Once appointed, all employees are required to report any suspicious behaviour or activities directly to the MLRO for further review and investigation.

Reporting
In cases where Coinstradehub suspects that a user is involved in money laundering, terrorist financing, or any other illegal activities, it will promptly report such suspicions to the appropriate governmental and regulatory authorities. Coinstradehub is prohibited from notifying users of any suspicious transaction reports (STRs) made in relation to their activities.

Record-Keeping

Coinstradehub will maintain transaction records for a minimum period of ten (10) years from the date of transaction completion, or for any other period required by applicable law. Additionally, all information collected for Anti-Money Laundering (AML) and Know Your Customer (KYC) purposes will be retained throughout the duration of the business relationship with the user and for ten (10) years after the relationship ends, or for such other minimal period as required by law.

Appendix A – Data sources checked by Comply Advantage

OFAC Consolidated List – United States
European Union Sanctions List – Europe
HM Treasury List – United Kingdom
Canada OSFI Entity List – Canada
Canada OSFI Person List – Canada
Canada’s Freezing Assets of Corrupt Foreign Officials – Canada
Public Safety Canada Listed Entities – Canada
Special Economic Measures Act – Sanctions – Canada
Canadian Sanctions Justice for Victims of Corrupt Foreign
Officials Act – Canada
DFAT Australia List – Australia
France Liste Unique de Gels – France
Federal Public Service National Financial Sanctions – Belgium
Liste des Sanctions Financières Internationales – Luxembourg
Swiss SECO List – Switzerland
Swiss Federal Council Freezing of Foreign Illicit Assets (Ukraine, Tunisia) -Switzerland
Singapore MAS List – Singapore
Singapore First Schedule of the Terrorism (Suppression of Financing) Act – Singapore
India Ministry of Home Affairs Banned Organisations – India
Israel Ministry of Defence – Israel
Russian ROSFIN Monitoring List – Russia
Ukraine State Financial Monitoring Blacklist – Ukraine
Norway Lovdata Judicial Laws – Norway
Monaco Ministerial Orders – Monaco
Sanction Netherlands Domestic Terrorist List – Netherlands
US State Department Nonproliferation Sanctions – United States
US Department of State Terror Exclusion List – United States
US Department of State Cuba Restricted Entities List – United States
Japan Ministry of Finance Sanctions – Japan
Japan METI – Weapons of Mass Destruction Proliferators – Japan
New Zealand Police Designated Terrorists – New Zealand
Australian National Security Terrorism List – Australia
Thailand Designated Persons List – Thailand
Kenyan Gazette – Sanctioned Entities – Kenya
Economic and Financial Crimes Commission Warnings and Convictions – Nigeria
Nigeria Securities Exchange Commission – Nigeria
South Africa Police Service – South Africa
African Development Bank Debarment and Sanctions – South Africa
Mauritius Independent Commission Against Corruption – Mauritius
Australian National Security Terrorism List – Australia
Australia ARPA Disqualifications – Australia
Australia ASIC Notices – Australia
Australia Disqualified Officers – Australia
ASIC Disqualified Organisations – Australia
China Securities and Futures Commission Enforcements – China
Warnings China Economic Fugitives – China
Hong Kong Most Wanted – Hong Kong
Hong Kong Monetary Authority – Hong Kong
Hong Kong Securities Futures Commission – Hong Kong
CBI Wanted List – India
Security and Exchange Board Enforcement – India
India NIA Most Wanted – India
India CBI Reward List – India
India CBI Red Yellow List – India
India Competition Commission – India
Japan Financial Services Agency – Japan
Japan Ministry of Economy Trade And Industry – Japan
Bank Negara Malaysia Enforcement Actions – Malaysia
Malaysia Securities Commission Compounded Cases – Malaysia
Malaysia Securities Commission Administrative Actions – Malaysia
Malaysia Securities Commission Criminal Prosecutions – Malaysia
Securities Commission Malaysia – Sanctions – Malaysia
Bank Negara Malaysia – Invalid Licenses – Malaysia
Bank Negara Malaysia – Companies receiving Warning Letters – Malaysia
New Zealand FMA – New Zealand
New Zealand Police – New Zealand
New Zealand Putea Matua Reserve Bank – New Zealand
New Zealand Serious Fraud Office – New Zealand
Philippines Police Most Wanted – Philippines
Philippines Securities and Exchange Commission – Philippines
Singapore Police Force – Singapore
Singapore Monetary Authority – Singapore
Thailand Securities and Exchange Commission – Thailand
Special Inspector General for Afghanistan Reconstruction – Afghanistan
Albania State Police Wanted – Albania
Austria FMA Investors Warnings List – Austria
Azerbaijan Most Wanted – Azerbaijan
Belgium Federal Police Wanted – Belgium
Court of Bosnia and Herzegovina Cases – Bosnia and Herzegovina
Cyprus Securities and Exchange Commission Warnings – Cyprus
Office for the Protection of Competition – Czech Republic
Denmark Finanstilsynet Warnings – Denmark
Danish Financial Services Authority Warnings – Denmark
EU Most Wanted – Europe
European Commission Banned Airlines – Europe
European Bank ineligible entities – Europe
FIN-FSA Finanssivalvonta Finansinspektionen – Finland
Hellenic Capital Market Commission – Greece
Guernsey Registry – Disqualified Directors and Involuntary Strike-Offs – Guernsey
Gazdasagi Versenyhivatal Decisions – Hungary
Hungarian Competition Authority – Hungary
Central Bank Warnings – Ireland
Companies Registration Office – Ireland
Ireland Revenue Defaulters List – Ireland
Isle of Man Employment Decisions Tribunals – Isle of Man
Isle of Man Courts Ordinary Procedure – Isle of Man
FSC Disqualified Commission – Isle of Man
Israel Antitrust Authority Enforcement Activity – Israel
Banca D’Italia Disciplinary Measures – Italy
National Bank of Kazakhstan – Kazakhstan
Commission de Surveillance du Secteur Financier – Luxembourg
Malta Financial Intelligence Unit Administrative Penalties – Malta
Individual Voluntary Arrangement Register – Northern Ireland
Pakistan National Accountability Bureau – Pakistan
Polish Financial Supervision Authority – Poland
Comissão Do Mercado De Valores Mobiliários – Portugal
Romania Most Wanted List – România
Saudi Arabia Washington Embassy – Saudi Arabia
Finansinspektionen – Sweden
Switzerland FINMA Unauthorized Services – Switzerland
Tajikistan Ministry of Internal Affairs Wanted – Tajikistan
Dubai Financial Services Authority Alerts – United Arab Emirates
FCA Warnings – United Kingdom
UK Crimestoppers Most Wanted – United Kingdom
Financial Services Commission Public Statements – Jersey
Court of Appeal Criminal Division – United Kingdom
United Kingdom Serious Fraud Office – United Kingdom
National Crime Agency Most Wanted – United Kingdom
FCA Final Notices – enforcement – United Kingdom
Disqualified Directors Register – United Kingdom
FCA Unauthorised Firms and Individuals – United Kingdom
Solicitors’ Disciplinary Tribunal – United Kingdom
The Gazette – Insolvency Notices – United Kingdom
Alberta Securities Commission Decisions and Orders – Canada
British Columbia Securities Commission Cease Trade Orders – Canada
British Columbia Securities Commission Disciplined Persons List – Canada
British Columbia Securities Commission Denied Persons List – Canada
British Columbia Insurance Council Disciplinary Decisions – Canada
Calgary Police Service – Canada
Canada Border Services Agency Wanted – Canada
Canadian Securities Administrators Disciplined Persons – Canada
Canada Chartered Professional Accountant of Ontario – Canada
Canada Competition Bureau – Canada
Canada Investment Industry Regulatory Organisation – Canada
Canada Law Society Tribunal – Canada
Canada Mutual Fund Dealers Association Enforcement Hearings – Canada
Public Notice Of Administrative Monetary Penalties – Canada
Canada Public Notices Financial Transactions and Reports Analysis Center – Canada
Royal Canadian Mounted Police Wanted List – Canada
Canadian Securities Commission – Canada
Canadian Securities Commission Investor Alerts – Canada
Canada OSFI Warnings Notices – Canada
Edmonton Police Service – Canada
Manitoba Insurance Council Disciplinary Decisions – Canada
Manitoba Securities Commission – Canada
Montreal Exchange Disciplinary Decisions – Canada
New Brunswick Financial and Consumer Services Tribunal – Canada
Newfoundland and Labrador Cease Trade Orders – Canada
Ontario Financial Services Commission Enforcement Activities – Canada
Ontario Provincial Police – Canada
Ontario Securities Commission – Canada
Peel Regional Police – Canada
Québec Chambre De La Sécurité Financière – Canada
Québec Bureau de Décision et de Révision – Canada
Québec Secretariat of the Council of the Treasury – Canada
Saskatchewan Financial Services Commission Cease Trade Orders – Canada
Saskatchewan Insurance Councils Disciplinary Decisions – Canada
Toronto Most Wanted – Canada
Alabama Baldwin and Etowah County Inmates – United States
Alabama Calhoun County Inmates – United States
Alabama Cherokee and Franklin County Inmates – United States
Alabama Department of Corrections – United States
Alabama Fayette County Inmates – United States
Alabama Medicaid Suspended Providers – United States
Arkansas Department of Health Excluded Providers List – United States
Arkansas Real Estate Commission Warnings – United States
Chicago Board Options Exchange Disciplinary – United States
Connecticut Department of Social Services Administrative Actions List – United States
District of Columbia Excluded Parties List – United States
FBI Most Wanted – United States
Federal Deposit Insurance Corporation Failed Bank List – United States
FINCEN Money Laundering Concern List – United States
Florida Agency for Healthcare Admin Medicaid Sanctioned Providers – United States
Florida Department of Corrections – United States
Foreign Agents Registrations – United States
Georgia OIG Exclusions List – United States
Guantanamo Bay Detainees – United States
Hawaii Medicaid Excluded Providers – United States
Inter-American Development Bank – United States
Kentucky Medicaid Termination and Exclusion List – United States
Louisiana Department of Health Hospitals Exclusion List – United States
Maine Medicaid Exclusion List – United States
Maryland Department of Health Mental Hygiene Exclusions List – United States
Massachusetts Health and Human Services List of Suspended or Excluded Masshealth Providers – United States
Michigan Department of Community Health List of Sanctioned Providers – United States
Minnesota Department of Human Services Excluded Provider Lists – United States
Mississippi Gaming Commission Exclusion List – United States
Missouri Department of Social Services Medicaid List of Terminated Providers – United States
Montana Excluded or Terminated Medicaid Providers – United States
Nevada Gaming Control Board Excluded – United States
Nevada GCB Most Wanted – United States
New Jersey Office of the State Comptroller Consolidated Debarment Report – United States
New York Office of the Medicaid Inspector General List of Exclusions – United States
NYSE Non-Compliant Issuers – United States
NYSE Regulation: Disciplinary Actions – United States
Ohio Department of Corrections Wanted – United States
SEC Trading Suspensions – United States
US Air Force Fugitives – United States
US Arizona Department of Insurance – United States
US Army Most Wanted – United States
US Bureau of Alcohol Tobacco Firearms and Explosives Commission Most Wanted – United States
US Consumer Financial Protection Bureau – United States
US DEA Fugitives – United States
US Department of Commerce Denied Persons – United States
US Department of Housing and Urban Development Limited Denials of Participation – United States
US Department of State Consent Agreements – United States
US FDA Clinical Investigators Disqualification Proceedings – United States
US FDA Debarment List – United States
US FFIEC Failed Bank List – United States
US Financial Industry Regulatory Authority – United States
US Georgia Bureau of Investigation – United States
US Immigration and Customs Wanted – United States
US Indiana Most Wanted List – United States
US Marshals Wanted – United States
US Medicaid Exclusions Lists OIG LEIE – United States
US OCC Enforcement Actions List Archive – United States
US Office of the Comptroller of the Currency – United States
US Pennsylvania General Services Department Debarment List – United States
US Postal Inspection Service Most Wanted – United States
US Redding Most Wanted – United States
US Rewards for Justice – United States
US Securities and Exchange Commission Unregistered Soliciting Entities – United States
US State Department AECA Debarments – United States
US System for Award Management Exclusions – United States
US Nasdaq Trader PHLX Disciplinary Actions – United States
Latin America and Caribbean Bahamas Central Bank Bahamas Belize Warning Notices – Belize
Bermuda Monetary Authority – Bermuda
Brazil Civil Police Wanted – Brazil
Brazil National Register of Punished Companies CNEP – Brazil
Brazil National Registry of Ineligible And Suspended Companies – Brazil
Brazil Policia Federal Most Wanted List – Brazil
Brazil Register of Non-Profit Entities CEPIM – Brazil
Brazil Registration of Federal Administration Expulsions (CEAF) – Brazil
Brazil Warnings Polícia Civil Rio Grande do Sul Wanted – Brazil
British Virgin Islands Financial Services Commission British Virgin Islands Chile Unidad de Análisis Financiero – Chile
Colombian Financial Superintendence – Colombia
Costa Rica Superintendencia General De Seguros – Costa Rica
México Comisión Nacional Bancaria y De Valores – Mexico
Debarred Entities Asian Development Bank – International
Sanctioned Entities Inter-American Development Bank – International
Wanted Listed Interpol – International
Announcements United Nations – International
Debarred List World Bank – International
Investor Alerts International Organization of Securities Commissions – International