Document Owner: Compliance Team
Effective Date: 15-March-2025
Review Period: Bi-Annually (or as required by regulatory changes)
Applicability: CoinPort Pty Ltd

1. Purpose

CoinPort Pty Ltd (“the Company”) is committed to maintaining robust Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) controls in compliance with Australian law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).

This Transaction Monitoring Program (TMP) ensures:

  • Detection and reporting of suspicious transactions.
  • Compliance with AUSTRAC’s regulatory requirements.
  • Prevention of financial crime (money laundering, terrorism financing, fraud, and sanctions evasion).
  • Integration with KYC (via KYCAID) and KYT (via KYCAIC) systems.

2. Scope

This policy applies to:

  • All fiat and cryptocurrency transactions processed on the CoinPort exchange, which is operated by CoinPort Pty Ltd.
  • Customers, employees, and third-party service providers interacting with the exchange.
  • Real-time and retrospective transaction monitoring.

3. Transaction Monitoring Framework

3.1. Risk-Based Approach

  • High-risk customers (e.g., Politically Exposed Persons, high-volume traders) undergo enhanced due diligence (EDD) and stricter monitoring.
  • Low-risk customers are subject to standard monitoring.

3.2. Monitoring Systems & Tools

  • KYCAID – Used for customer identity verification (KYC).
  • KYCAIC – Implements Know Your Transaction (KYT) for real-time blockchain analysis.
  • Automated Transaction Monitoring System (TMS) – Flags unusual activity based on predefined rules.

3.3. Key Risk Indicators (KRIs) & Red Flags

Transactions are monitored for:

  • Unusual Transaction Patterns:
    • Rapid deposits/withdrawals with no clear purpose.
    • Structuring (breaking large transactions into smaller amounts to avoid reporting).
    • Transactions linked to high-risk jurisdictions.
  • Anomalous Behavior:
    • Mismatched customer profiles (e.g., a low-income user suddenly trading large volumes).
    • Use of privacy coins or mixers (if permitted by CoinPort Pty Ltd’s policy).
  • Sanctions & PEPs:
    • Transactions involving blacklisted wallets or sanctioned entities.

4. Procedures

4.1. Real-Time Monitoring

  • All transactions are screened against:
    • Sanctions lists (e.g., OFAC, AUSTRAC).
    • KYT alerts (unusual wallet activity, darknet links).
  • Automated holds are placed on suspicious transactions pending review.

4.2. Post-Transaction Review

  • Daily batch reviews of flagged transactions by the Compliance Team.
  • Manual investigation where automated systems generate alerts.

4.3. Suspicious Matter Reporting (SMR)

  • If a transaction is deemed suspicious, an SMR is filed with AUSTRAC within 24–72 hours.
  • Internal documentation is maintained for audit purposes.

4.4. Record Keeping

  • All monitoring data, alerts, and investigation notes are stored for 7 years per AML/CTF Act requirements.

5. Roles & Responsibilities

Role Responsibility
Compliance Officer Oversees TMP, files SMRs, updates policies.
KYCAID/KYCAIC Teams Ensures KYC/KYT data feeds into monitoring.
IT/Security Team Maintains monitoring systems and data integrity.
Customer Support Assists in freezing accounts if fraud is suspected.

6. Training & Awareness

  • Staff receive annual AML/CTF training, including transaction monitoring protocols.
  • Compliance Team undergoes specialized KYT/KYC training for crypto risks.

7. Review & Updates

  • This policy is reviewed annually or after:
    • Regulatory changes (AUSTRAC updates).
    • New financial crime trends.
    • System upgrades (KYCAID/KYCAIC integrations).

8. Policy Approval

Approved by: [Compliance Officer/CEO Name]
Date: [Insert Date]

Appendix A: Example Red Flags

  • A user deposits $9,000 multiple times to avoid the $10,000 threshold.
  • A customer receives funds from a darknet-linked wallet.
  • A new account suddenly trades $100,000+ with no prior history.