POLICY
TOKEMY.CH AML & CFT 
Policy Money laundering is defined as the process by which the identity of proceeds of crime is concealed so that it appears as legitimate income. Criminals specifically target financial services firms to launder illicit funds without the firm’s knowledge or suspicion. In response to the scale and impact of money laundering, the European Union has enacted Directives designed to combat money laundering and terrorist financing. These Directives, together with applicable regulations, rules, and industry guidance, form the cornerstone of AML/CFT obligations and define the offenses and penalties for non-compliance. Whilst TOKEMY.CH is currently unregulated and may not fall within the full scope of AML/CFT regulatory obligations, senior management has implemented systems and procedures aligned with European Union standards. This reflects a clear commitment to preventing financial crime and ensuring that the platform is not used for illicit purposes. Anti-Money Laundering (AML) Policy The AML Policy of TOKEMY.CH is designed to prevent money laundering and terrorist financing by aligning with European standards. It ensures the implementation of adequate systems and controls to mitigate the risk of the platform being used for financial crime. This AML Policy establishes the following minimum standards: Appointment of a Money Laundering Reporting Officer (MLRO) with sufficient seniority and independence, responsible for overseeing compliance with applicable laws, regulations, and guidance; Adoption of a Risk-Based Approach (RBA) for assessing and managing money laundering and terrorist financing risks; Implementation of Customer Due Diligence (CDD), identification, verification, and Know Your Customer (KYC) procedures, including enhanced due diligence for higher-risk clients such as Politically Exposed Persons (PEPs); Ongoing monitoring of customer activity through risk-based systems and procedures; 
  • Establishment of internal procedures for reporting suspicious activity to relevant authorities;
  • Maintenance of appropriate records for the legally prescribed retention periods;
  • Provision of continuous staff training and awareness programs.
 Mandatory Source Validation Protocol In accordance with global AML/CFT standards, TOKEMY.CH may require users to execute a certified transfer of funds originating exclusively from the primary funding source(s) used to initially fund their account. These sources may include cryptocurrency wallets, exchanges, or other financial intermediaries. The required amount will be determined based on a comprehensive evaluation of transactional behavior, cumulative activity, and risk profiling analytics. Failure to comply with this requirement may result in account restrictions, including but not limited to: 
  • Limitations on withdrawals
  • Restrictions on trading activity
  • Suspension of operational functionalities
  • Sanctions Policy
 TOKEMY.CH strictly prohibits transactions involving individuals, entities, or jurisdictions subject to international sanctions. The platform conducts screening against the following sanctions lists: 
  • United Nations (UN)
  • European Union (EU)
  • UK Treasury (HMT)
  • U.S. Office of Foreign Assets Control (OFAC)
This screening is applied across all jurisdictions in which TOKEMY.CH operates.