Compliance Policy
Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CTF)
The Republic of Poland has implemented regulations governing virtual currency activities in alignment with European Union directives, including the Anti-Money Laundering Act. This includes entities engaged in the business of dealing in virtual currencies, such as exchanges between virtual currencies and fiat currencies, exchanges between virtual currencies, intermediation in such exchanges, and operating related accounts. These entities are classified as "obliged institutions" under the Act of 1 March 2018 on Counteracting Money Laundering and Terrorism Financing (the "AML Act") and must register in the Register of Virtual Currency Activities.
Localcoin is registered with the Ministry of Finance in the Register of Virtual Currency Activities, which is maintained by the Tax Administration Chamber in Katowice. We are in the process of transitioning to comply with the Markets in Crypto-Assets Regulation (MiCAR), effective from 30 December 2024, including potential authorization as a Crypto-Asset Service Provider (CASP) by the Polish Financial Supervision Authority (KNF) under the grandfathering provisions until 31 December 2025.
Localcoin has developed internal policies and procedures with respect to AML/CTF requirements that reflect the company’s commitment to managing money laundering and terrorist financing (“ML/TF”) risks that Localcoin faces.
Localcoin fully cooperates with the General Inspector of Financial Information (GIIF), government, and law enforcement requests to aid in the fight against money laundering and terrorist financing.
The Act on Counteracting Money Laundering and Terrorism Financing (AML Act) and associated regulations In accordance with the legislative requirements, Localcoin is required to fulfill certain identification, record-keeping, and reporting requirements as an obliged institution.
Localcoin has implemented a compliance regime which includes the mandated requirements to:
- Designate a person responsible for the implementation of AML/CTF obligations, who acts as an independent oversight function and who is granted the necessary authority to fulfill their responsibilities under Localcoin’s AML/CTF Policy and who is mandated to;
- Develop and implement a suite of compliance policies and procedures, which include:
- Conduct an assessment of risks as it relates to ML/TF - both of our business and of each user individually;
- Completing customer due diligence (“CDD”) procedures on users at specified regulatory and risk-based thresholds (including sanction & PEP screening), with enhanced measures for high-risk scenarios such as transactions involving politically exposed persons or high-risk countries;
- Monitor all user transactions for potentially suspicious and attempted suspicious activities for the purposes of filing notifications of suspicious transactions to GIIF (including screening for sanctioned wallets and assets);
- Maintain the associated and required records per Localcoin’s record-keeping procedures required by law, including retention for at least five years from the end of the business relationship or occasional transaction;
- Maintain and provide written, ongoing compliance training for our employees to ensure their understanding of their responsibilities under our compliance regime; and,
- Complete an independent periodic review of our compliance regime to test its effectiveness every two years.
*Please note that transaction limits at Localcoin prevent customers from meeting the value levels that require compliance with certain reporting obligations, such as those under the Transfer of Funds Regulation (TFR) for transfers exceeding EUR 1,000.