Anti-Money-Laundering (AML) & Know-Your-Customer (KYC) Policy
1. Purpose and commitment
TOKENSDESK is a trading name of PRIMARYMARKETS PTY LTD (ACN 136 368 244, ABN 24 136 368 244), a company registered in Australia with the Australian Securities & Investments Commission. We are committed to preventing the platform from being used for money laundering, terrorism financing, fraud, sanctions evasion or any other financial crime.
Our customer due diligence programme is written to the standards of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the AML/CTF Rules administered by AUSTRAC, Australia's financial intelligence agency, and to the recommendations of the Financial Action Task Force (FATF). It operates on a risk-based approach: the depth of the checks is proportionate to the risk a relationship presents.
2. Summary of what this means for you
| Obligation | What we do |
|---|---|
| Identify every client | Government photo identification and proof of address before you can trade or withdraw (section 4) |
| Source of funds | Required only for leverage above 1:20 (section 4, Level 3) |
| Restricted jurisdictions | We do not accept clients from four named jurisdictions, or from any sanctioned territory (section 3) |
| Sanctions screening | Clients are screened at onboarding and on an ongoing basis (section 6) |
| Ongoing monitoring | Transactions are monitored against your stated profile for the life of the relationship (section 7) |
| Third-party funding | Not accepted, in either direction (section 8) |
| Reporting | Suspicious matters are reported to AUSTRAC; tipping off is prohibited by law (section 9) |
| Record keeping | Seven years after the relationship ends (section 11) |
3. Restricted jurisdictions
We do not open or maintain accounts for any person who is resident in, located in, a citizen of, or acting from any jurisdiction in which we are not authorised to offer the service, or in which doing so would require an authorisation, registration or self-regulatory membership we do not hold. This includes the United States of America, its territories and possessions, and any “US person”: retail trading of contracts for difference on digital assets is not permitted under the rules of the Commodity Futures Trading Commission and the Securities and Exchange Commission, with neither of which we are registered.
We maintain a restricted-jurisdiction list which is reviewed at least annually and whenever the regulatory position in a market changes. It is applied at onboarding, on every subsequent login, and on an ongoing basis against the client’s stated residence and the location their connection originates from. The list is not published in full.
Jurisdictions subject to a Financial Action Task Force call for action, and jurisdictions subject to comprehensive sanctions, are refused in all circumstances and cannot be onboarded by any route, including where a client’s stated residence is elsewhere.
Separately from the list above, we do not deal with any person or entity subject to sanctions administered by the Australian Government (DFAT), the United Nations Security Council, the United States Office of Foreign Assets Control, the United Kingdom or the European Union, nor with any person located in a territory subject to comprehensive sanctions.
We also apply enhanced due diligence — not an automatic refusal — to clients connected with jurisdictions the FATF has placed under increased monitoring, and to any jurisdiction our own risk assessment identifies as high risk.
4. Client due diligence: the three levels
Verification is arranged in three levels. Each opens as the one before it is completed.
Level 1 — Identity
A clear photograph or scan of one government-issued photo document, valid and unexpired, with all four corners and every detail legible:
- Passport
- National identity card
- Driving licence
- Residence permit
We record your full name, date of birth, nationality and the document number and expiry.
Level 2 — Address
A document dated within the last three months showing your name and residential address:
- Bank or credit-card statement
- Utility bill — electricity, gas, water
- Council tax, telephone or internet bill
- A government-issued letter showing your address
A mobile-phone bill alone, a post-office box, or a document from a business address is not accepted. Address verification is how a restricted jurisdiction is identified, so it cannot be skipped.
Levels 1 and 2 are submitted together and reviewed as a single decision. Until both are approved you cannot trade or withdraw.
Level 3 — Source of funds
Required only if you want leverage above 1:20. Everyone else may ignore it. We accept:
- A bank statement showing the funds and their origin
- Payslips
- A tax return or assessment
- Evidence of a sale of assets or property
- An investment or brokerage statement
- Other documentary evidence, considered case by case
Level 3 cannot begin until Levels 1 and 2 are approved: evidence about where money came from means nothing until we know whose money it is.
Accepted formats
JPG, PNG or PDF, up to 10 MB per file. Screenshots of a document displayed on another screen, photographs with obscured fields, edited images and expired documents are rejected. We may ask for a further document or a clearer copy at any time.
5. Enhanced due diligence
We apply additional checks where the risk is higher, including:
- Politically exposed persons (PEPs), their family members and close associates — senior management approval is required before the relationship is established or continued;
- clients connected with a FATF-monitored or otherwise high-risk jurisdiction;
- unusually large deposits, or activity inconsistent with the profile you gave us;
- funding from a wallet with an adverse blockchain-analytics result;
- any case where we cannot satisfy ourselves about the source of funds.
Enhanced due diligence may include further documentation, a video verification call, and closer ongoing monitoring.
6. Sanctions screening
Every client is screened at onboarding and on an ongoing basis against the sanctions and watch lists named in section 3, and against PEP and adverse-media data.
A confirmed match means the relationship is refused or terminated, funds are dealt with as the applicable sanctions law requires — which may mean freezing rather than returning them — and the matter is reported where reporting is required. Where the law prohibits us from telling you, we will not tell you.
7. Ongoing monitoring
Verification is not a one-off event. For the life of the relationship we monitor activity against the profile you gave us and investigate what does not fit, including:
- deposits or withdrawals that are large relative to your stated means;
- funding in, and immediate withdrawal out, with little or no trading in between;
- a pattern of transactions structured to stay below a reporting threshold;
- a sudden change in trading behaviour, counterparties or funding wallets;
- any attempt to route funds to or from a third party.
We may ask you at any time to explain a transaction or to re-verify your identity, and we may suspend activity on the account until you do. Identification records are refreshed periodically and whenever your circumstances change.
8. Funding rules
- No third-party funding. Deposits must come from a wallet you control, and withdrawals are paid only to a wallet in your name. We do not accept or make payments for anyone else.
- Return to source. Wherever possible, funds are returned by the route they arrived.
- Correct network only. Each deposit address is issued per asset and per network. Assets sent on the wrong network are generally unrecoverable.
- No cash. We do not accept cash in any form.
- Blockchain analytics. Deposit and withdrawal addresses may be screened against known illicit-activity data. A deposit from a sanctioned or high-risk address will be investigated and may be frozen or reported.
9. Reporting
Where we form a suspicion on reasonable grounds that a matter relates to money laundering, terrorism financing or another serious offence, we submit a suspicious matter report to AUSTRAC within the statutory time limit. We also make any threshold transaction reports and international funds transfer reports the law requires.
10. Governance and training
An AML/CTF Compliance Officer is appointed at management level and is responsible for this programme, for reporting to AUSTRAC and for escalation to the board. The programme is documented, approved by the board, and reviewed at least annually and whenever the business, the law or our risk assessment changes. It is subject to independent review at appropriate intervals.
All staff receive AML/CTF training on appointment and at least annually, covering identification procedures, red flags, escalation and the tipping-off prohibition.
11. Records
We keep identification records, verification documents, transaction records and the reasoning behind decisions for seven years after the end of the client relationship or after the transaction, as the AML/CTF Act requires.
Documents are stored in a private, access-controlled store, are never published at a public address, and are visible only to authorised staff whose access is logged. See the Privacy Policy for the detail.
12. If verification cannot be completed
If you do not complete verification, or the documents cannot be accepted:
- you cannot trade and you cannot withdraw;
- any deposit already made is returned to the wallet it came from, unless the law requires otherwise;
- the account is closed after a reasonable period, and we tell you so far as we are permitted.
We do not keep a client's funds because verification failed. We return them, subject to the sanctions and reporting obligations above.
13. Contact
Questions about this policy, or about a request we have made of you, go to [email protected]. Complaints follow the process in section 19 of the Terms & Conditions.
Related documents: Terms & Conditions · Privacy Policy