AML/KYC Policy

NexaLuxury is committed to preventing money laundering, terrorist financing, and other illicit financial activities. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the measures we take to detect, prevent, and report suspicious activities.

We comply with:

• Financial Action Task Force (FATF) recommendations.
• Applicable international anti-money laundering laws and regulations.
• Local regulatory guidelines on virtual digital assets where applicable.

3.1 Basic Verification (Tier 1)

• Email verification during registration.
• Valid for transactions up to $100 USD equivalent per day.

3.2 Enhanced Verification (Tier 2)

• Government-issued photo ID (Passport, National ID, Driving License).
• Selfie verification for identity confirmation.
• Required for transactions exceeding $100 USD per day or $500 USD per month.

3.3 Enhanced Due Diligence (EDD)

• Applied to high-risk customers or unusual transaction patterns.
• Additional documentation including proof of source of funds.
• Ongoing monitoring of transaction activity.

We employ automated and manual systems to monitor for:

• Transactions that exceed defined thresholds.
• Unusual patterns of activity (structuring, layering).
• Transactions involving high-risk jurisdictions.
• Multiple accounts linked to the same identity.
• Rapid movement of funds without economic purpose.
• Transactions linked to sanctioned addresses or entities.

• We utilize blockchain analytics to trace the origin and destination of funds.
• Wallet addresses are screened against known illicit address databases.
• Transactions from mixing services, darknet markets, or sanctioned entities are flagged.
• We maintain records of all blockchain analysis performed.

• Suspicious transactions are escalated to our Compliance Officer.
• Suspicious Transaction Reports (STRs) are filed with the Financial Intelligence Unit (FIU-IND) as required.
• We cooperate fully with law enforcement investigations.
• Users will not be notified when a report is filed (tipping off is prohibited).

• All users are screened against international sanctions lists including OFAC, UN, and EU sanctions.
• Ongoing monitoring ensures compliance with updated sanctions lists.
• Accounts matching sanctioned individuals or entities will be immediately frozen.

• All KYC documents are retained for a minimum of 5 years after account closure.
• Transaction records are maintained for at least 5 years.
• Records of suspicious activity reports are kept indefinitely.

• All staff receive AML/KYC training upon joining and annually thereafter.
• Training covers identification of suspicious activities, reporting procedures, and regulatory updates.
• Records of training completion are maintained.

We reserve the right to:

• Suspend or terminate accounts that fail KYC verification.
• Freeze accounts pending investigation of suspicious activity.
• Decline transactions that do not meet our compliance standards.
• Request additional documentation at any time.

Our designated Compliance Officer oversees the implementation of this policy. For AML/KYC-related inquiries, contact heythere@nexa.luxury.