Minax is a brand exchange operated by Minax Holding Co., Ltd, accessible via www.minax.io. The Minax platform provides customers with services to buy, sell, and exchange brand assets. As an entity governed by Dubai laws, Minax is obligated to implement financial security measures in line with international standards.
To maintain the integrity of the platform and prevent its use for money laundering, terrorism financing, or other illegal activities, Minax has developed and implemented comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) policies. This document outlines Minax’s policies and measures in AML/KYC compliance to ensure the detection and prevention of illegal activities.
Minax is committed to adhering to the highest international standards in AML and CTF compliance, aiming to prevent, detect, and report activities related to money laundering, terrorism financing, or other illegal actions.
Definition and Threat of Money Laundering
Money laundering refers to the process of converting funds obtained through illegal means (e.g., terrorism, corruption, or drug trafficking) into seemingly legitimate assets, thereby obscuring their true origins. To prevent the inflow of criminal funds into the economy, governments and regulators actively combat money laundering and terrorism financing. As a financial services platform, Minax takes on the responsibility of preventing criminal activities on a global scale.
Our AML and CTF Measures
- Customer Due Diligence (CDD)
- Conduct comprehensive due diligence on customers, including identity verification and ongoing transaction monitoring.
- Track abnormal or suspicious transaction operations.
- In the event of potential illegal activity, Minax reserves the right to request additional verification or cancel transactions.
- According to international regulations, customers are not entitled to specific reasons for account or transaction monitoring.
- Enhanced Compliance Measures
- Establish robust internal compliance procedures, including technological upgrades and staff training.
- Implement risk-based AML/CTF strategies, ensuring resources are prioritized for high-risk areas.
- All customers must comply with the KYC process and adhere to our policies.
- Policy Scope
This policy applies to all employees, managers, directors, and all products and services offered by Minax. - Governance and Oversight
- The board of directors assumes ultimate responsibility for AML/CTF compliance.
- Senior management is accountable for policy implementation.
- A designated AML compliance officer oversees daily operations, ensuring policy execution and regulatory adherence.
Customer Identification Program (CIP)
Minax verifies customer identity through a strong CIP, including:
- Verifying government-issued identification documents (e.g., passports, ID cards, driver’s licenses).
- Providing proof of address (e.g., utility bills or bank statements dated within six months).
- Conducting enhanced due diligence (EDD) for high-risk customers, such as requiring proof of fund sources.
Transaction Monitoring
- Systematic Monitoring: Combining automated systems with manual processes to monitor suspicious transactions. Any suspicious activities will be reported to relevant authorities as required by law.
- Ongoing Monitoring: Continuously monitor customer transactions and activities to identify suspicious or potentially illegal actions. This includes tracking unusual transaction patterns, such as multiple transactions of similar amounts, or transactions inconsistent with customer profiles or typical behavior. We also monitor transactions involving high-risk countries, politically exposed persons, or other individuals or entities subject to sanctions or regulatory measures.
Legal Reporting
In case of suspicious activities, Minax will file Suspicious Activity Reports (SARs) with relevant regulatory authorities in compliance with Dubai and international regulations.
Record Retention
- Customer transaction and identity verification records will be securely stored for a minimum of five years and made available to regulators as required.
Risk Management
- Risk-Based Approach: Conduct dynamic risk assessments based on factors such as customer transaction history and country of origin. High-risk customers must provide additional verification documents.
- Risk Review: Regularly review potential risks associated with high-risk countries, politically exposed persons (PEPs), and high-value transactions.
Employee Training and Awareness
- Provide all employees with onboarding and annual AML/CTF training, covering topics such as identifying suspicious activities, reporting procedures, and legal obligations.
Internal Controls and Audits
- Conduct regular internal and external audits to continuously monitor compliance activities and optimize policies in line with updated regulations.
International Standards Compliance
- Strictly adhere to international standards (e.g., FATF recommendations) and adjust policies periodically based on regulatory updates.
Sanction Screening and Independent Reviews
- Sanction Screening: Use automated tools to screen customers and transactions against international sanction lists.
- Independent Review: Regularly analyze gaps between policies and industry best practices and develop improvement plans.
Data Privacy and Protection
- Employ advanced data protection technologies (e.g., encryption and multi-factor authentication) and breach response mechanisms to ensure the security of customer information.
Prohibited Businesses and Jurisdictions
- Minax prohibits transactions with individuals or entities from high-risk countries and jurisdictions, as well as customers or businesses involved in illegal activities (see Appendix for details).
Contact Us
If you have any questions, please contact us via customer support at support@minax.io.
Appendix A: Prohibited Jurisdictions
Minax does not conduct business with individuals or entities from the following countries and regions:
- Afghanistan
- Angola
- Belarus
- Bosnia and Herzegovina
- Burundi
- Central African Republic
- Democratic Republic of the Congo
- Cuba
- Ethiopia
- Guinea
- Guinea-Bissau
- Guatemala
- Iran
- Iraq
- North Korea
- Kosovo
- Lebanon
- Liberia
- Libya
- Mali
- Myanmar
- Nagorno-Karabakh
- Nicaragua
- Northern Cyprus
- North Korea
- Russian Federation
- Sahrawi Arab Democratic Republic
- Somaliland
- Somalia
- South Ossetia
- South Sudan
- Sudan
- Syria
- Tunisia
- Turkey
- Venezuela
- Yemen
- Zimbabwe
- Ukrainian regions: Luhansk, Donetsk, Crimea, and other occupied territories
Appendix B: High-Risk Jurisdictions
When dealing with individuals or entities from the following high-risk countries, Minax will enhance due diligence and restrict transactions:
- Albania
- American Samoa
- Anguilla
- Antigua and Barbuda
- Aruba
- Azores (Portuguese territory)
- Bahamas
- Bahrain
- Bangladesh
- Barbados
- Belize
- Bermuda
- Botswana
- British Virgin Islands
- Brunei Darussalam
- Bulgaria
- Burkina Faso
- Burundi
- Cambodia
- Cameroon
- Cayman Islands
- Central African Republic
- Chad
- Chile
- China
- Colombia
- Comoros
- Republic of the Congo
- Cook Islands
- Costa Rica
- Croatia
- Curaçao
- Djibouti
- Dominica
- Egypt
- Equatorial Guinea
- Eritrea
- Fiji
- French Polynesia
- Gaza Strip
- Gibraltar
- Guernsey
- Haiti
- Honduras
- Hong Kong
- India
- Isle of Man
- Israel
- Jamaica
- Jersey
- Jordan
- Kenya
- Kyrgyzstan
- Madagascar
- Malaysia
- Maldives
- Marshall Islands
- Mauritania
- Mauritius
- Montserrat
- Morocco
- Mozambique
- Namibia
- Nauru
- Niger
- Nigeria
- Niue
- North Macedonia
- Pakistan
- Palau
- Panama
- Philippines
- Qatar
- Saint Helena, Ascension, and Tristan da Cunha
- Saint Martin (French)
- Saint Pierre and Miquelon
- Samoa
- Senegal
- Seychelles
- Solomon Islands
- South Africa
- Saint Kitts and Nevis
- Tajikistan
- Tanzania
- Thailand
- Tonga
- Trinidad and Tobago
- Turkmenistan
- Turks and Caicos Islands
- Uganda
- United Arab Emirates
- U.S. Virgin Islands
- Uruguay
- Uzbekistan
- Vanuatu
- Vietnam
- West Bank (occupied Palestinian territories)
Appendix C: Unacceptable Business Types
Minax prohibits transactions with the following types of businesses or activities:
- Shell banks
- Anonymous shell companies
- Businesses involved in illegal drug trade
- Unlicensed gambling and betting services
- Unlicensed money services businesses (MSBs)
- Arms and ammunition dealers
- Businesses involved in human trafficking or exploitation
- Prostitution and escort services
- Ponzi schemes and other pyramid sales schemes
- Businesses involved in the production or distribution of pornography
- Unregistered charities and non-profit organizations
- Businesses involved in the sale of counterfeit goods
- Unlicensed foreign exchange platforms
- Businesses or activities involving the exploitation of children
- Cryptocurrency mixing services or tumblers
- Businesses dealing in stolen goods
- Any other business or activity deemed illegal by regulatory authorities
Note: Customers engaged in the above activities will be subject to strict scrutiny and may be denied access to Minax services.
Appendix D: Required Documents
According to verification requirements, Minax customers must provide the following documents:
Identity Verification Documents
- Government-issued international passport
- Government-issued ID card
- Government-issued driver’s license
- Selfie with identification document
Address Verification Documents
- Utility bill or bank statement issued within the last six months (paper or electronic versions are acceptable)
- Documents must be clear and unaltered
Additional Verification Documents
- Proof of funds
- Proof of source of wealth
Note: All documents must be provided in high-quality format, ensuring that content is clear, legible, and free from tampering or editing.