Purpose and scope
33366 maintains an anti-money laundering and countering the financing of terrorism (AML/CFT) program designed to comply with applicable laws. This policy governs all users, accounts, and transactions conducted on or through the platform and applies to every business area that handles customer information, payments, and compliance reporting.
Regulatory framework and supervisory oversight
33366 operates under the jurisdictional AML/CFT framework appropriate to its operations and is subject to supervision by the competent supervisory authority. The Company shall implement and maintain controls, record-keeping, and reporting obligations in line with applicable law and shall update this policy in response to regulatory developments or material risk changes.
Governance and compliance structure
The AML/KYC program is overseen by a designated Compliance Officer who reports to senior management. The Compliance Officer is responsible for implementing this policy, approving risk-based procedures, coordinating regulatory reporting, and ensuring staff awareness and adherence across all functions.
Know Your Customer (KYC) and customer identification
- At account registration, all customers must provide accurate personal information and valid identification to establish identity and eligibility.
- Acceptable documents include government-issued identification (e.g., passport or national ID) and proof of residential address (e.g., utility bill or bank statement).
- The user shall provide documents personally; joint or third-party accounts are prohibited, and any attempt to share or transfer ownership constitutes a breach of terms.
- Customers are afforded a 30-day window to complete the verification process. Failure to verify within this period will result in account restrictions consistent with regulatory and policy requirements and may affect access to features and funds.
Verification timelines and consequences
Account verification must be completed within 30 days of registration. If verification is not completed within the timeframe, the account may be restricted, limiting participation in certain activities and the ability to initiate withdrawals until verification is completed.
Enhanced Due Diligence (EDD)
33366 may apply enhanced due diligence for customers assessed as high-risk based on profile, transaction patterns, or geography. EDD may include additional identity checks, sourcing of funds verification, or site visits where permitted by law and regulation, to mitigate money laundering and financing of terrorism risks.
Ongoing monitoring and suspicious activity reporting
33366 conducts ongoing monitoring of customer accounts and transactions to identify unusual or suspicious activity. This includes review of patterns such as rapid onboarding of multiple accounts, structuring attempts, or activity involving high-risk jurisdictions or individuals. Suspicious activities are documented and reported to the competent authorities in accordance with applicable law and regulatory requirements.
Transaction monitoring thresholds
The Company maintains automated monitoring for transactions exceeding defined risk thresholds within a 24-hour period. The current threshold triggering heightened review is 10,000 USD in 24 hours; thresholds may be adjusted in response to regulatory guidance, risk assessments, or changes in applicable law.
Withdrawals and verification policy
Withdrawals are available only to verified accounts. The identity and ownership of funds must be validated prior to processing withdrawals. Withdrawals may be withheld or suspended if verification is incomplete or if findings indicate potential AML/CFT risk until resolution is achieved.
Record keeping and data retention
33366 retains all customer identification data and transaction records for the period required by applicable laws and regulations. Records shall be stored securely and retained in a manner that supports regulatory audits and investigations while protecting data subject rights.
Third-party obligations
All third-party service providers engaged by 33366 are contractually required to comply with AML/KYC policies and procedures and to furnish relevant information and reports as required by law. The Company conducts ongoing oversight of third-party AML/KYC compliance as part of vendor management.
Employee training and awareness
33366 provides regular AML/KYC training for employees, tailored to role and risk exposure, and keeps training materials current with evolving regulations. Training records are maintained to support internal and regulatory examinations.
Compliance officer and communications
A designated compliance officer oversees AML/KYC compliance and has direct access to senior management. The officer can request documentation, approve or suspend processes, and coordinate regulatory communications in accordance with internal procedures.
Privacy, data protection, and information sharing
Personal data collected for AML/KYC purposes is processed in accordance with applicable privacy laws. Information may be shared with regulatory authorities or other entities as required by law or as necessary to fulfill AML/CFT obligations, with appropriate safeguards to protect data subject rights.
Dormant and inactive accounts
Inactivity beyond defined periods may trigger administrative measures, including notifications and potential restrictions on activity until AML/KYC requirements are reassessed and resolved.
Age, eligibility, and account integrity
Participation is restricted to individuals aged 18 years or older. The Company may verify age and identity; accounts identified as underage or associated with prohibited circumstances will be closed or restricted in accordance with policy and applicable law. The Company prohibits duplicate or shared accounts and reserves the right to suspend or close accounts at its sole discretion where violations are detected.
Policy review and updates
This AML/CFT Policy is reviewed on a regular basis to reflect regulatory changes and risk assessments. Material updates shall be communicated to customers in a timely manner, and customers may terminate participation if they do not accept the updated terms.