AML and Sanctions statement
As a Dutch regulated financial institution, Prosper Digital Assets B.V. (“Prosper”) and all its subsidiaries and affiliated companies must comply with prevailing Anti Money Laundering, Sanctions and all other applicable laws and regulations in jurisdictions Prosper operates in.
Anti Money Laundering and Counter Terrorist Financing
Money laundering is the process where the origin of the proceeds of crime is disguised to give it an impression of legitimate income. Financial institutions are specifically targeted in an attempt to launder criminal proceeds by placement, layering and integration through the financial system.
Terrorist financing, on the other hand, can have a legitimate or illegitimate source, but is subsequently used to fund terrorist acts. Financial institutions are targeted to move funds to terrorist organisations and/or affiliates.
In response to the scale and effect of money laundering and terrorist financing, the European Union has passed several Directives to combat these crimes, which have been transposed into Dutch local law. These Directives, local laws, other regulations, rules and industry guidance form the cornerstone of Prosper’s AML/CFT policy.
Sanctions
Prosper does not enter in relationships or perform transactions in/for individuals, companies or countries that are on prevailing sanctions lists. Prosper therefore applies continuous monitoring and screening of new customers and its customer base against sanction lists established by, among others, the European Union, United Nations, United States and the United Kingdom.
AML and Sanctions statement
The minimum standards that must be adhered to in order to mitigate the risks Prosper is being exposed to in terms of inadvertently facilitating money laundering, terrorist financing or other financial crime or transacting with a sanctioned person, company or country and to ensure compliance with prevailing laws and regulations are as follows:
Appointing a Chief Compliance Officer with sufficient knowledge, experience and independence in AML/CFT, Sanctions, regulatory requirements and the crypto industry, with the responsibility to ensure compliance with relevant regulations, rules and industry guidance;
Establishing and maintaining a risk based approach to Customer Due Diligence, including the onboarding, monitoring and exit procedures and risk based measures such as enhanced due diligence for high risk customers;
Establishing and maintaining screening of all individuals, companies and countries, and their affiliates on prevailing Sanctions lists on a continuous basis;
Blocking and terminating all business activities of Sanctioned persons, companies or countries;
Implementing systems and innovative solutions to detect and report suspicious activity to relevant authorities;
Providing training and raising awareness on AML and Sanctions for all relevant employees;