AML/CTF Policy

Last Updated: Jun 25, 2023

Australian Anti-Money Laundering (AML)/Counter-Terrorism Financing (CTF)

Cube acknowledges the inherent risk that its platform, like all cryptocurrency providers, may be exploited for money laundering and terrorism financing purposes. To effectively address and minimize this risk, Cube has implemented comprehensive training, robust mitigating controls, and streamlined processes that fully adhere to the AML/CTF legislation regulated by AUSTRAC. These measures are in place to safeguard the integrity of the industry, maintain the reputation of our business, and fulfill our role as a responsible corporate entity operating in Australia and Globally.

Background

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines the measures and procedures implemented by Cube to ensure compliance with the regulations set forth by the Australian Transaction Reports and Analysis Centre (AUSTRAC) for the prevention of money laundering and terrorist financing activities. Cube is committed to conducting thorough customer due diligence, monitoring transactions, reporting suspicious activities, and maintaining records.

Message from the Board

Cube Group Inc is committed to preventing, detecting and deterring Money Laundering and Terrorist financing and has a zero-tolerance policy in regards to Money Laundering and Terrorist Financing. To accomplish this, Cube Group Inc implemented a culture where it is the responsibility of every employee in the company to comply with Cube Group Inc AML/CTF program and all related legislations administered and enforced by Australian regulators.

AUSTRAC (Australian Transaction Reports and Analysis Centre)

Is the Australian Government agency responsible for detecting, deterring and disrupting criminal abuse of the financial system to protect the community from serious and organized crime.

Money laundering defined

Money laundering is defined as the process used to disguise, or attempt to disguise, the source of funds or assets derived/sourced from criminal or illicit activity.

3 typical stages of the process:

  • Placement: initial deposit of proceeds of crime into the financial system, placement may or may not include the predicate offense from which illicit funds were derived.
  • Layering: conducting multiple transactions and/or transfers to convert illicit funds to another form and obfuscate the true source/original placement. Layering may include transferring the value from one vehicle/object to another including purchase of high value assets (jewelry, vehicles, property) and multiple money transfers from one instrument to another (money orders, checks, bearer bonds, prepaid cards, etc.). Multiple BTC or other crypto transactions between related wallets is a perfect example of layering.
  • Integration – withdrawal or conversion of the funds to a “clean” form.

Terrorist Financing Defined

Terrorist financing is the application of funds/assets, whether legitimately derived or not, to fund terrorist activities and organizations. Funds may be sourced from donations, real business activities, AND from criminal sources such as drug/human trafficking and other illicit industries.

Please reach out to compliance@cube.exchange for any questions or concerns.

The latest AML/CTF Policy changes were made on Jun 25, 2023

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