```markdown

Politically Exposed Persons (PEP) Policy

Effective Date: 05/06/2025
Version: 1.0
Owner: Compliance Team, CoinPort

1. Purpose

CoinPort is committed to maintaining robust Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) controls in accordance with Australian laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). This policy outlines CoinPort’s approach to identifying, assessing, and managing risks associated with Politically Exposed Persons (PEPs) to mitigate potential money laundering and terrorist financing threats.

2. Scope

This policy applies to:

  • All customers (individuals and entities) of CoinPort.
  • Employees, contractors, and third-party service providers engaged in customer onboarding or due diligence.

3. Definition of a PEP

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position, domestically or internationally, and may pose a higher risk of corruption, bribery, or financial crime due to their influence.

3.1 Categories of PEPs

  • Domestic PEPs: Individuals holding prominent roles in Australian government or public offices (e.g., MPs, judges, senior military officials).
  • Foreign PEPs: Individuals holding equivalent positions in foreign governments or international organisations.
  • International Organisation PEPs: Senior members of international bodies (e.g., UN, IMF, World Bank).
  • Family Members & Close Associates: Immediate family (spouse, children, parents) or individuals closely linked to a PEP.

4. PEP Identification & Due Diligence

4.1 Customer Onboarding

  • All new customers must undergo identity verification and screening against PEP databases (e.g., World-Check, Dow Jones).
  • Enhanced Due Diligence (EDD) is required for confirmed or suspected PEPs.

4.2 Enhanced Due Diligence (EDD)

For PEPs, CoinPort will:

  1. Obtain senior management approval before establishing a business relationship.
  2. Verify the source of wealth and funds.
  3. Conduct ongoing monitoring of transactions and account activity.
  4. Reassess risk ratings annually or upon material changes.

5. Risk Mitigation Measures

  • Restricted Services: PEPs may be subject to limitations on certain high-risk products.
  • Ongoing Monitoring: Unusual or high-value transactions will trigger additional reviews.
  • Documentation: All PEP-related decisions and investigations must be recorded in the AML/CTF compliance register.

6. Reporting Obligations

  • Suspicious Matter Reports (SMRs) must be filed with AUSTRAC if illicit activity is suspected.
  • PEP status alone does not constitute suspicious activity but warrants heightened scrutiny.

7. Training & Awareness

  • All employees handling customer onboarding or compliance must complete annual AML/CTF training, including PEP identification procedures.

8. Record Keeping

  • PEP-related records must be retained for 7 years per AML/CTF Act requirements.

9. Policy Review

This policy will be reviewed annually or following regulatory changes.

Approved By: [Peter Cooney, CFO]
Date: [05/06/2025]