(hereinafter referred to as the “AML/KYB Policy”)
The purpose of this AML/KYB Policy is to prevent GradientXChange from being involved, directly or indirectly, in any illegal or illicit activities through the use of its aggregator platform.
In line with international and domestic regulatory obligations, GradientXChange implements internal procedures and controls to mitigate risks associated with money laundering, terrorist financing, human and drug trafficking, proliferation of weapons, corruption, and bribery. This includes taking appropriate action in response to any suspicious activity reported or identified from businesses utilizing its services.
This AML/KYB Policy addresses the following areas:
GradientXChange does not directly collect KYC information from individual end users. Instead, it performs Know Your Business (KYB) checks for companies and platforms integrating its API or widget.
KYB procedures may involve:
GradientXChange reserves the right to request updated documentation or additional information from a business partner if any unusual or high-risk activity is detected.
All business data collected will be handled securely and in accordance with GradientXChange’s Privacy Policy and applicable regulatory requirements.
GradientXChange monitors the businesses using its services to ensure compliance with AML/KYB requirements, even though it does not directly onboard end users or process their transactions.
Monitoring measures may include:
Any irregularities or suspected violations are escalated to the Compliance Officer for further evaluation and, if necessary, reporting to relevant regulatory authorities.
The Compliance Officer is authorized to enforce adherence to the AML/KYB Policy and is responsible for:
GradientXChange employs a risk-based approach to evaluate the businesses that utilize its platform. Risk factors considered include:
Businesses assessed as high-risk, such as those with unclear ownership, unusually large or frequent transaction patterns, or operations in higher-risk jurisdictions, will undergo enhanced due diligence.
GradientXChange retains the right to: