GroveX ("GroveX", "we", "us", or "our") is committed to maintaining a safe, secure, and compliant digital asset platform. This policy describes the Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) controls GroveX applies to help prevent money laundering, terrorist financing, sanctions evasion, fraud, and other financial crime.
1. Definitions
Unless otherwise defined in this policy, the following terms apply:
- AML (Anti-Money Laundering): Laws, regulations, controls, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.
- CDD (Customer Due Diligence): The process of identifying and verifying a customer and assessing the money laundering and terrorism financing risks associated with that customer.
- CTF (Counter-Terrorism Financing): Measures designed to prevent funds or assets from being provided, collected, or used to finance terrorist activity.
- Digital Currency / Digital Asset: A digital representation of value that can be digitally traded and may function as a medium of exchange, unit of account, or store of value.
- EDD (Enhanced Due Diligence): Additional and more rigorous review applied to higher-risk customers, transactions, counterparties, or activity.
- KYC (Know Your Customer): The process of identifying and verifying customers and assessing relevant risks associated with the business relationship.
- MLRO (Money Laundering Reporting Officer): A senior compliance officer responsible for oversight of AML/CTF controls, escalation, and suspicious activity reporting where required.
- PEP (Politically Exposed Person): A person entrusted with a prominent public function, or a relevant family member or close associate, who may present increased bribery, corruption, or financial-crime risk.
- Platform: The GroveX website, mobile applications, APIs, and related services made available by GroveX.
- RBA (Risk-Based Approach): An approach under which compliance resources and controls are applied proportionately to identified financial-crime risk.
- Suspicious Activity Report: A report made to a competent authority where required in relation to activity suspected of being connected with money laundering, terrorism financing, fraud, sanctions evasion, or other financial crime.
- Source of Funds (SOF): The origin of funds used for a transaction or activity.
- Source of Wealth (SOW): The origin of a person's overall wealth or assets.
- Terrorist Financing: The provision or collection of funds or assets, directly or indirectly, with the intention or knowledge that they may be used in connection with terrorist activity.
- Transaction Monitoring: Ongoing review of customer transactions and account activity to identify unusual or suspicious patterns.
- User / Customer: Any individual or entity accessing or using GroveX's Platform or Services.
2. Introduction
GroveX maintains an AML/CTF and KYC framework designed to meet applicable legal and regulatory requirements and align with relevant international financial-crime prevention standards.
The framework includes customer due diligence, risk assessment, ongoing monitoring, sanctions screening, enhanced due diligence, record keeping, escalation, and reporting procedures intended to prevent misuse of the Platform for money laundering, terrorist financing, fraud, sanctions evasion, and other financial crime.
3. Verification Levels and Customer Due Diligence
GroveX applies a risk-based and tiered approach to verification. The level of information or documentation requested may depend on factors including:
- Identification Provided: The type, quality, completeness, and validity of identification or verification information supplied.
- Risk Profile: The risk associated with the customer's profile, jurisdiction, activity, counterparties, products used, and transaction behaviour.
- Ongoing Compliance: Whether the customer continues to satisfy monitoring, verification, and review requirements.
- Transaction Risk: Transaction size, frequency, destination, source, wallet risk indicators, unusual patterns, or other relevant risk factors.
GroveX may assign, review, increase, reduce, or otherwise change a customer's verification requirements where reasonably necessary for compliance, security, or risk management. Access to some Platform functionality, including deposits, trading, or withdrawals, may be limited or restricted until required checks are completed.
GroveX may require KYC, re-verification, Source of Funds, Source of Wealth, or other supporting information at any time where required by law, regulatory requirements, internal risk controls, transaction monitoring, security review, or third-party service requirements.
GroveX may also restrict or refuse access to Services based on jurisdiction, sanctions exposure, customer risk, transaction risk, or other legitimate compliance considerations.
4. User Responsibilities
Users play an important role in GroveX's AML/CTF and KYC controls. Users are responsible for:
- Providing accurate, complete, truthful, current, and genuine information and documents when requested.
- Promptly updating information where circumstances change.
- Maintaining the security and confidentiality of passwords, authentication methods, account credentials, and devices.
- Immediately notifying GroveX of suspected unauthorised access, fraud, compromise, or suspicious activity involving their Account.
- Responding to reasonable KYC, EDD, Source of Funds, Source of Wealth, transaction, beneficiary, or compliance enquiries.
- Complying with this policy, GroveX Terms of Service, Terms & Conditions, and other applicable Platform rules and policies.
- Not using the Platform for money laundering, terrorism financing, sanctions evasion, fraud, scams, theft, market manipulation, or any other unlawful or prohibited activity.
5. AML / CTF Compliance Governance
GroveX maintains controls and procedures designed to support effective financial-crime risk management.
Money Laundering Reporting Officer
A designated senior compliance function oversees GroveX's AML/CTF framework, reviews escalated matters, supports internal investigations, and coordinates reporting to competent authorities where required.
Risk-Based Approach
GroveX applies a Risk-Based Approach to identify, assess, and mitigate money laundering, terrorism financing, sanctions, fraud, and related financial-crime risks. Risk assessments may consider geographic exposure, customer characteristics, products and services, transaction patterns, counterparties, wallet activity, Source of Funds, Source of Wealth, and other relevant indicators.
EDD may be applied to higher-risk customers and activity, including PEPs, higher-risk jurisdictions, unusual transaction behaviour, elevated blockchain risk, complex ownership structures, or other circumstances identified through GroveX's internal risk assessment.
Sanctions Compliance
GroveX applies sanctions screening and controls intended to prevent prohibited dealings with sanctioned persons, entities, wallets, counterparties, or jurisdictions. Screening may use applicable national and international sanctions lists and reputable third-party risk intelligence.
Customer Identification and KYC Procedures
GroveX may conduct identity verification during onboarding, when particular Services are requested, when risk thresholds are reached, during account recovery, and at periodic or event-driven intervals. GroveX may use reliable independent data sources and specialist third-party verification providers.
Ongoing Monitoring
GroveX monitors transactions and account activity through automated and manual controls. Monitoring may identify unusual transaction volumes or frequencies, rapid movement of funds, high-risk sources or destinations, exposure to known illicit addresses, darknet markets, scams, stolen funds, ransomware, mixers, sanctions exposure, structuring, account takeover indicators, or activity inconsistent with a customer's expected profile.
Suspicious Activity Reporting
GroveX maintains internal escalation procedures for potentially suspicious activity. Relevant matters may be escalated to the compliance function and, where legally required, reported to competent regulatory or law-enforcement authorities. GroveX may be prohibited from informing a customer that a suspicious activity report, investigation, or regulatory disclosure has been made.
Record Keeping
GroveX retains KYC information, transaction records, relevant correspondence, risk assessments, and AML/CTF records securely for the periods required by applicable law, regulatory obligations, internal policy, and legitimate risk-management requirements. Records are maintained to support an appropriate audit trail of material compliance actions and decisions.
Staff Training
Relevant GroveX personnel receive AML/CTF and KYC training appropriate to their responsibilities. Training may cover regulatory obligations, internal procedures, sanctions, customer due diligence, transaction monitoring, suspicious activity indicators, escalation procedures, and emerging financial-crime typologies.
Technology and Blockchain Analytics
GroveX may use automated monitoring, blockchain analytics, identity-verification technology, risk-scoring systems, security analytics, and reputable specialist service providers to support AML/CTF, KYC, fraud prevention, sanctions screening, and investigation processes.
Data Security and Privacy
Personal information collected for KYC, AML/CTF, fraud prevention, and compliance purposes is handled in accordance with the GroveX Privacy Policy and applicable data-protection requirements. GroveX applies technical and organisational safeguards that may include encryption, access controls, logging, monitoring, and secure storage.
Independent Review and Audit
GroveX may conduct periodic internal reviews and independent assessments of its AML/CTF framework to evaluate effectiveness, identify weaknesses, and support continuous improvement.
Cooperation with Authorities
GroveX cooperates with competent law-enforcement agencies, courts, regulators, and other authorised bodies where legally required, including responding to valid requests for information, legal process, and financial-crime investigations.
6. Right to Refuse, Restrict, or Suspend Services
GroveX may decline onboarding, restrict Platform functionality, delay or refuse transactions, place holds, require additional verification, suspend an Account, freeze access to assets where legally permitted or required, or terminate Services where a User does not satisfy AML/CTF or KYC requirements, presents heightened risk, or where such action is reasonably necessary for compliance, security, fraud prevention, sanctions controls, investigation, or protection of the Platform and its Users.
Non-compliance with this policy may result in restrictions, suspension, termination, asset holds or freezes where permitted by law, and reporting to competent authorities where required.
7. Policy Review and Updates
This AML / CTF & KYC Policy may be reviewed and updated periodically, including when laws, regulatory expectations, technologies, products, risk indicators, or GroveX business practices change.
GroveX may update this policy at least annually or more frequently where reasonably necessary. Material updates will be communicated through the Platform or other appropriate channels where required.