CoinPort Pty Ltd Transaction Monitoring Program Policy Document Number: CP-COMP-007 Version: 2.0 Effective Date: 16-Jul-2026 Review Date: 16-Jul-2027
1.0 PURPOSE
This document sets out how CoinPort Pty Ltd (“CoinPort”) applies its transaction monitoring controls operationally. It is a process summary, not a separate monitoring methodology. The authoritative source for CoinPort’s transaction monitoring framework — risk-based thresholds, key risk indicators, red flags, Travel Rule obligations, and the full suspicious matter reporting process — is:
- AML/CTF Program v3.1 — Sections covering transaction monitoring, Travel Rule, enhanced due diligence triggers, and the suspicious matter reporting process
- Risk Assessment and Management Matrix (Appendix 3 to the AML/CTF Program) — CoinPort’s approved risk-scoring methodology by product, channel, and jurisdiction
This document does not restate or re-derive that framework. Maintaining a second, competing description of the same controls creates a real risk of drift between the two — this document is a thin operational layer pointing to the one methodology that actually governs transaction monitoring.
2.0 SCOPE
This applies to all fiat and digital asset transactions processed on the CoinPort exchange and P2P channels, and to CoinPort’s customers, employees, and third-party service providers with a role in transaction monitoring.
3.0 MONITORING SYSTEMS & TOOLS (ACTUAL, NOT ILLUSTRATIVE)
- Didit — CoinPort’s primary identity verification (KYC) provider, supplemented by Sumsub, with KYC-AID retained as a dormant fallback.
- AMLBot — blockchain analytics and wallet screening (Know Your Transaction / KYT), providing real-time screening for sanctioned wallet addresses, blacklisted exchanges, mixer/tumbler interactions, and darknet or ransomware associations, on all cryptocurrency deposits and withdrawals.
- TRUST — Travel Rule data exchange with counterparty VASPs.
- Sanctions screening is performed against the DFAT Consolidated List, OFAC, and UN sanctions lists, consistent with the AML/CTF Program. AUSTRAC is CoinPort’s regulator, not a sanctions list, and is not itself a screening source.
4.0 KEY RISK INDICATORS AND RED FLAGS
The authoritative list of transaction pattern red flags — including structuring, rapid fund movement, mismatched customer profiles, and high-risk jurisdiction or wallet exposure — is set out in the AML/CTF Program. This document does not reproduce that list; refer to the AML/CTF Program directly for the current, authoritative version.
5.0 OPERATIONAL PROCEDURES
5.1 Real-Time and Ongoing Screening
Transactions and wallet addresses are screened by AMLBot in real time, including sanctions screening at onboarding and daily thereafter, consistent with the AML/CTF Program.
5.2 Review of Flagged Activity
Alerts generated by AMLBot or CoinPort’s monitoring processes are reviewed by Nicanor Nuqui as AML/CTF Compliance Officer / MLRO, supported operationally by Peter Cooney and Jonathan Heywood where cross-functional input is needed (for example, a payment rail or custody question).
5.3 Suspicious Matter Reporting (SMR)
Where an employee forms a reasonable suspicion, the reporting line is: Employee → immediate supervisor → AML/CTF Compliance Officer → AUSTRAC. The AML/CTF Compliance Officer assesses whether an SMR is required and, if so, lodges it within the statutory timeframe set out in the AML/CTF Program. This document does not restate that timeframe as a separate figure — the AML/CTF Program is authoritative on statutory deadlines.
5.4 Record Keeping
All monitoring data, alerts, and investigation notes are retained for a minimum of seven years, consistent with the AML/CTF Program and Section 11 of the Compliance Manual.
6.0 ROLES AND RESPONSIBILITIES
| Role | Responsibility |
|---|---|
| Nicanor Nuqui — AML/CTF Compliance Officer / MLRO | Owns transaction monitoring; reviews flagged activity; assesses and lodges SMRs; owns this document |
| Peter Cooney — Primary Responsible Manager | Escalation point for monitoring matters with broader compliance or licensing implications |
| Jonathan Heywood — Operations Manager | Supports operational review of flagged activity and cross-functional escalation |
7.0 TRAINING & AWARENESS
Staff receive AML/CTF training annually, including transaction monitoring content, consistent with the AML/CTF Program’s Risk Awareness Training Program and the Employee Onboarding Policies and Procedures.
8.0 REVIEW AND AMENDMENT
This document is reviewed at least annually, and following any material change to the AML/CTF Program’s transaction monitoring framework, to ensure it remains an accurate summary rather than drifting out of alignment with the authoritative source. Amendments are approved by the AML/CTF Compliance Officer.
Document Control
| Version | Date | Change | Author |
|---|---|---|---|
| 1.0 | 15-Mar-2025 | Prior version — referenced fictional/incorrect tool names (“KYCAID” and “KYCAIC,” the latter not corresponding to any real CoinPort system), listed AUSTRAC as a sanctions list rather than the regulator, and referred to fictional teams (“Compliance Team,” “IT/Security Team,” “Customer Support,” “KYCAID/KYCAIC Teams”). Superseded in full. | (prior version) |
| 2.0 | 16-Jul-2026 | Complete rewrite as a thin operational summary pointing to the AML/CTF Program v3.1 and Risk Matrix (Appendix 3) as the single authoritative source for monitoring methodology, thresholds, and red flags. Corrected tools to Didit/Sumsub/KYC-AID (KYC) and AMLBot (KYT/blockchain analytics), corrected sanctions lists to DFAT/OFAC/UN, and corrected roles to Nicanor Nuqui, Peter Cooney, and Jonathan Heywood. | Jonathan Heywood |
Approvals:
AML/CTF Compliance Officer: Nicanor Nuqui Date: 16-Jul-2026
Primary Responsible Manager: Peter Cooney Date: 16-Jul-2026