SPARTAEX protects itself from involvement in any activity that facilitates money laundering or other criminal activities by following the UK AML legislation, FinCEN guidance for MSBs operating in the United States and AML legislation in countires where SPARTAEX have opened bank Accounts. SPARTAEX aims to reasonably identify each User by cross-checking User data against governmental watch lists such as the Specially Designated Nationals, Blocked Persons List (“SDN”) and Politically exposed Person list (PEP) maintained by the HM Treasury, Office of Financial Sanctions Implementation in UK and Office of Foreign Assets Control (“OFAC”) within the U.S. Department of Treasury, as well as through the utilization of 3rd party identity verification and authentication services. If a User or a User’s transaction is flagged as suspicious through our internal controls, SPARTAEX will require additional proof of identification from the User and has the right to not permit any trades, deposits, and/or withdrawals, receving and make payments until additional and verifiable proof of identity satisfactory to SPARTAEX in its sole discretion is received and SPARTAEX has approved the User for use of the Platform.
By agreeing to our Terms, you acknowledge and understand that SPARTAEX maintains verification levels which require User participation and verification in order to obtain, with leveled permissions based on User supplied information, our ability to verify it, and our internal policies. You accept that you may not be able to achieve a desired level of verification, and SPARTAEX reserves the right to determine, at its sole discretion, the appropriate verification level and criteria for any User, as well as the right to downgrade Users without prior notice. SPARTAEX may, from time to time, implement policies restricting verification levels and criteria by nationality, country of residence, or any other factor. This may affect your ability to withdraw Fiat and Digital Currency and you agree to indemnify, defend and hold harmless SPARTAEX against any losses associated with an inability to deposit and/or withdraw Fiat and Digital Currency based on the verification level assigned by SPARTAEX to your Account.
Whilst SPARTAEX are currently unregulated and do not fall with the scope of the AML/CTF obligations in the UK the senior management have implemented systems and procedures that meet the UK AML legislation. This decision reflects the senior managements desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
The SPARTAEX AML Policy is designed to prevent money laundering by meeting the UK AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
The maintenance of appropriate records for the minimum prescribed periods;
Training and awareness for all relevant employees