AML policy

1. Introduction and Scope

Cambeon Global is the trading name of Cambeon Global S.A., a cryptocurrency brokerage incorporated in the Republic of Panama under registration No. 155791256, with its registered office at Calle 50, Plaza 2000, Floor 17, Panama City, Republic of Panama (“Cambeon”, “we”, “us”, or “our”).

This Anti-Money-Laundering Policy (“AML Policy”) sets out the commitments, principles, and controls through which we work to prevent, detect, and report money laundering and the financing of terrorism in connection with our activities. Our activities include the intermediation of over-the-counter transactions involving fiat currencies and digital assets, including USDT, and a DeFi service organized in client-selected product series.

The money-laundering and terrorist-financing risks associated with these activities are assessed in accordance with the nature of the services provided, the characteristics of the clients and transactions involved, and the legal and regulatory requirements applicable to the relevant activities and jurisdictions.

This Policy applies to everyone who acts for or on behalf of Cambeon, including our directors, employees, contractors, and affiliates, and governs the treatment of prospective and existing clients, including the representatives, beneficial owners, and authorized users of institutional clients. It is designed to be consistent with the anti-money-laundering and counter-terrorist-financing obligations that apply to us in the Republic of Panama and with the recommendations of the Financial Action Task Force (FATF).

This Policy describes our approach at a general level. It is not a substitute for the terms of your client agreement with us, and it may be updated as our business and the applicable requirements evolve.

2. Definitions

Unless the context requires otherwise, the following terms have the meanings commonly used in anti-money-laundering practice and FATF terminology:

Money laundering (“ML”): the process of concealing the origin, ownership, or control of the proceeds of crime so that they appear to have come from a legitimate source.
Terrorist financing (“TF”): the provision or collection of funds, by any means, with the intention or knowledge that they are to be used to carry out terrorist acts or to support those who do.
Customer due diligence (“CDD”): identifying a client and verifying that identity using reliable, independent sources; identifying any beneficial owner; understanding the purpose and intended nature of the relationship; and conducting ongoing monitoring.
Beneficial owner: the natural person who ultimately owns or controls a client, or on whose behalf a transaction is conducted, whether that ownership or control is direct or indirect.
Politically exposed person (“PEP”): an individual who is or has been entrusted with a prominent public function, together with their family members and close associates.
Business relationship: a professional or commercial relationship between a client and Cambeon that is expected, at onboarding, to have an element of duration.
Ongoing monitoring: scrutinizing transactions and activity over the life of a relationship to ensure they are consistent with what we know about the client, and keeping CDD information up to date.

3. AML Program

We maintain a risk-sensitive anti-money-laundering program consisting of policies, procedures, systems, and controls that address client due diligence and monitoring, the reporting of suspicious activity, record-keeping, risk assessment, internal controls, and training.

Responsibility for the program sits with our compliance function, which administers it under the oversight of Cambeon’s management and can be reached at legal@cambeon.com. Cambeon retains responsibility for the governance and oversight of the program, including the activities performed on its behalf by the specialized third-party providers described in Section 5, and engaging those providers does not transfer Cambeon’s responsibilities under applicable law. Our compliance function oversees the program; it does not itself perform identity verification, which is carried out by those providers.

The program is communicated to the people who act for or on behalf of Cambeon, who are made aware of their responsibilities under it, and it is reviewed and updated on a risk-sensitive basis.

4. Risk-Based Approach

We apply a risk-based approach: the extent and nature of the due diligence and monitoring we apply are calibrated to the money-laundering and terrorist-financing risk presented by each relationship and transaction.

For each client we assess risk by reference to the client itself (including its nature, structure, and beneficial ownership), the product or service involved, the delivery or distribution channel, and the geographies connected to the relationship. We update that assessment on a risk-sensitive basis as new information arises.

Where higher risk exists, for example the involvement of a politically exposed person, connections to jurisdictions that do not sufficiently apply FATF standards, opaque ownership structures, or other higher-risk indicators, we apply enhanced due diligence and enhanced ongoing monitoring, which may include obtaining additional information, verifying source of funds or wealth, and applying closer scrutiny to activity. Where a relationship is non-face-to-face, we apply additional measures to mitigate the associated identity risk.

5. Client Acceptance and Due Diligence

We obtain and verify customer due diligence information for every client, relevant third party, and beneficial owner before establishing a business relationship, and we do not establish a relationship where the required due diligence cannot be completed.

Cambeon engages specialized third-party service providers to perform designated customer identification, identity verification, KYC/KYB, customer due diligence, and screening activities, and may share your information with them for that purpose. Such providers are selected and assessed according to the nature and quality of their services and their qualifications. The engagement of external providers does not relieve Cambeon of its responsibilities under applicable law. Cambeon retains responsibility for overseeing the outsourced arrangements and for determining whether a client relationship or transaction may proceed, based on the information obtained and the applicable risk assessment. The respective responsibilities of Cambeon and its service providers, including information access, record availability, escalation, and the treatment of deficiencies, are governed by contractual arrangements.

Timing. Due diligence is completed before onboarding and before a relationship is established or a transaction is executed. Where verification cannot be completed, we do not proceed, and an incomplete or failed verification results in the relationship not being established or being terminated.

Updating triggers. Due diligence information is refreshed when doubts arise about the adequacy or accuracy of the documents or data we hold, when changes occur to identification information, beneficial ownership, or control, and in the course of ongoing monitoring.

Ongoing monitoring. We monitor activity over the life of a relationship to ensure that it remains consistent with what we know about the client, and we keep client information up to date on a risk-sensitive basis.

Due diligence of individuals and representatives. For an individual or a representative acting for a client, the minimum information collected includes identity information evidenced by a valid government-issued identity document and proof of residential address. Documentation requirements increase with risk.

Due diligence of corporate clients (KYB). For a corporate client we obtain sufficient information to understand the client’s business, ownership, and control. The minimum documentation typically includes evidence of incorporation and good standing, the client’s registered office, and the identification of directors, authorized signatories, registered shareholders, and ultimate beneficial owners, together with the authorizations required to open and operate the relationship. We may request additional information where necessary.

6. Prohibited and Restricted Accounts

We do not open or maintain anonymous or numbered accounts, accounts in fictitious names, nominee accounts established to conceal the identity of the underlying owner, or any arrangement based on bearer instruments. A relationship must be attributable to an identified client and, where applicable, to identified beneficial owners.

7. Sanctions and High-Risk Countries

Sanctions and watchlist screening is mandatory and is performed on our behalf by the specialized third-party providers described in Section 5. Screening is applied at onboarding and on an ongoing basis. Where digital-asset transactions are involved, this screening includes checking the wallet addresses associated with a relationship against applicable sanctions lists and recognized sources of known illicit addresses.

We do not establish or continue a relationship with a person who is subject to applicable sanctions, and we assess the risk connected to the jurisdictions involved in a relationship. Rather than reproduce a fixed list, we apply screening against the sanctions and watchlist sources our providers maintain and treat as higher-risk the countries that FATF identifies from time to time as having strategic deficiencies or as not sufficiently applying its standards, as those designations are updated.

8. Introducing Brokers

Cambeon may receive client introductions from independent introducing brokers and other commercial partners. An introduction is a commercial referral only: the introducing party does not perform customer due diligence, and we do not rely on it to do so. Regardless of how a client is introduced, every client is subject to Cambeon’s due diligence and risk assessment, which is carried out through the arrangements described in Section 5.

9. Record-Keeping

We keep records of the risk assessments, due diligence information, identity evidence, and transaction and relationship documentation needed to support our program and to allow activity to be reconstructed, and we maintain them so that they can be retrieved for competent authorities. We do not apply a single fixed retention period: identity, onboarding, and transaction records collected for anti-money-laundering and other legal purposes are kept for at least the minimum period required by the laws that apply to us, after which they are deleted or anonymized.

10. Monitoring, Testing, and Training

We maintain procedures to monitor and test the effectiveness of our anti-money-laundering program and of the related training. Our compliance function and the appropriate staff have timely access to the due diligence and transaction records they need to perform their duties.

The people who act for or on behalf of Cambeon receive training appropriate to their role on our anti-money-laundering obligations and on how to identify and handle transactions or behaviour that may indicate money laundering or terrorist financing.

11. Reporting of Suspicious Activity

Where activity gives rise to a suspicion of money laundering or terrorist financing, it is escalated to our compliance function for consideration and, where appropriate or required, reported to the competent authorities in accordance with applicable law. As a company incorporated in Panama, we apply customer due diligence and ongoing monitoring and comply with the anti-money-laundering, counter-terrorist-financing, and sanctions obligations that apply to us, including reporting to the competent authorities where required.

To meet those obligations we may be required to request further information, delay or decline a transaction, freeze or restrict assets or access, or terminate a relationship, and in some cases we may be prohibited by law from telling you that a report has been made or why.

12. Refusal and Termination

Where the required due diligence cannot be applied before a relationship is established or a transaction is executed, we do not proceed with the relationship. Where ongoing monitoring cannot be performed, or where continuing a relationship would be inconsistent with this Policy or with the obligations that apply to us, the relationship is terminated. We may also refuse or terminate a relationship where we are required to do so by applicable law.

13. Client Acknowledgement

By engaging with us, you acknowledge that you have read and understood this AML Policy and that we are required to apply the due diligence, screening, monitoring, and reporting measures it describes. When you register as a client, you are required to confirm that you have read and agree to this Policy and our other policies; you cannot complete registration without doing so, and by completing registration you represent that you have read, understood, and accepted them.

14. Contact

For questions about this AML Policy, you may contact us at legal@cambeon.com or at Calle 50, Plaza 2000, Floor 17, Panama City, Republic of Panama.