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Anti-Money Laundering and Counter-Terrorism Financing Policy

Last Updated: December 2024

1. Introduction

Dexbit (Pty) Ltd ("Dexbit", "we", "us", or "our") is committed to preventing the use of our platform for money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering and Counter-Terrorism Financing ("AML/CFT") Policy outlines our commitment to compliance with the Financial Intelligence Centre Act 38 of 2001 ("FICA"), the Financial Action Task Force ("FATF") recommendations, and all applicable South African laws and regulations.

2. Regulatory Framework

As a Crypto Asset Service Provider ("CASP") operating in South Africa, Dexbit is registered with and regulated by the Financial Sector Conduct Authority ("FSCA"). We comply with:

  • Financial Intelligence Centre Act 38 of 2001 (FICA)
  • Financial Intelligence Centre Amendment Act 1 of 2017
  • Protection of Constitutional Democracy Against Terrorist and Related Activities Act 33 of 2004
  • FSCA Crypto Asset Declaration
  • FATF Recommendations and Guidelines

3. Customer Due Diligence (CDD)

We implement robust Customer Due Diligence procedures to verify the identity of all users:

3.1 Standard Due Diligence

  • Full legal name verification
  • Date of birth confirmation
  • South African Identity Document or valid passport
  • Proof of residential address (not older than 3 months)
  • Contact information verification

3.2 Enhanced Due Diligence (EDD)

Enhanced measures are applied for high-risk customers, including:

  • Politically Exposed Persons (PEPs)
  • Customers from high-risk jurisdictions
  • High-value transactions
  • Complex ownership structures
  • Unusual transaction patterns

4. Know Your Customer (KYC) Requirements

All users must complete our KYC verification process before accessing full platform functionality:

Tier 1 - Basic Verification

  • Email and phone verification
  • Basic personal information
  • Limited transaction capabilities

Tier 2 - Full Verification

  • Government-issued ID document
  • Proof of address
  • Selfie verification
  • Full platform access

Tier 3 - Enhanced Verification

  • Source of funds documentation
  • Source of wealth declaration
  • Additional documentation as required
  • Higher transaction limits

5. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect suspicious activities:

  • Real-time transaction screening
  • Pattern recognition algorithms
  • Threshold-based alerts
  • Blockchain analytics integration
  • Sanctions list screening
  • PEP database checks

6. Suspicious Activity Reporting

In accordance with FICA, we are obligated to report suspicious and unusual transactions to the Financial Intelligence Centre (FIC):

  • Suspicious Transaction Reports (STRs) are filed within prescribed timeframes
  • Cash Threshold Reports (CTRs) for transactions exceeding R24,999.99
  • Terrorist Property Reports as required
  • All reports are treated with strict confidentiality

7. Record Keeping

We maintain comprehensive records in compliance with FICA requirements:

  • Customer identification records - minimum 5 years after account closure
  • Transaction records - minimum 5 years from date of transaction
  • Communication records - minimum 5 years
  • All records stored securely and available for regulatory inspection

8. Prohibited Activities

The following activities are strictly prohibited on our platform:

  • Money laundering or attempting to launder proceeds of crime
  • Terrorist financing or providing support to terrorist organizations
  • Proliferation financing
  • Sanctions evasion
  • Fraud, market manipulation, or insider trading
  • Using the platform on behalf of undisclosed third parties

9. Staff Training

All Dexbit employees receive regular AML/CFT training covering:

  • Legal and regulatory requirements
  • Recognition of suspicious activities
  • Reporting procedures
  • Customer due diligence requirements
  • Record-keeping obligations

10. Compliance Officer

Dexbit has appointed a dedicated Compliance Officer responsible for:

  • Overseeing AML/CFT compliance program
  • Liaising with the Financial Intelligence Centre
  • Conducting internal audits and risk assessments
  • Updating policies and procedures
  • Staff training and awareness programs

11. Contact Information

For AML/CFT related queries, please contact our Compliance Department:

Email: compliance@dexbit.co.za
Address: P and L Building Right Wing, C/O Frikkie Meyer Blvd and Kelvin Blvd, Vanderbijlpark, Gauteng, 1911