Orbix Trade Co., Ltd. ("the Company") is committed to preventing the Company from being a source of money laundering, financing of terrorism, proliferation of weapons of mass destruction, fraud, and corruption in all forms, which could impact the Company's reputation, image, and security. The Company emphasizes compliance with laws on anti-money laundering, counter-terrorism financing, and the proliferation of weapons of mass destruction, including the Digital Asset Business Decree, regulations of the Bank of Thailand, and other relevant authorities' regulations.
The Company has established the Anti-Money Laundering and Counter Terrorism and Proliferation of Weapon of Mass Destruction Financing Policy to guide employees in their operations in accordance with the Emergency Decree on Digital Assets Business Operation, including laws and regulations from the Bank of Thailand and other government agencies.
The Board of Directors is responsible for approving the AML/CTPF policy, emphasizing the prevention of money laundering, financing of terrorism, and the proliferation of weapons of mass destruction.
Top Management is responsible for overseeing employees' compliance with anti-money laundering laws, counter terrorism and proliferation of weapon of mass destruction financing laws, the Digital Asset Business Decree, regulations of the Bank of Thailand, and other relevant authorities' regulations.
Employees must strictly comply with this policy, company procedures, orders, and manuals, as well as, the Digital Asset Business Decree, regulations of the Bank of Thailand, and other relevant authorities' regulations.
Compliance Department is responsible for:
a. The Company has processes for establishing or rejecting business relationships or transactions with customers, agents, partners, and representatives both domestically and internationally.
b. The Company rejects business relationships or transactions with customers, agents, partners, and representatives who conceal their real names, use aliases, or use false names.
c. The Company rejects business relationships or transactions with customers, agents, partners, and representatives who do not cooperate in providing identification documents or information for customer due diligence.
d. The Company rejects business relationships or transactions with individuals, groups, legal entities, or organizations listed by the United Nations Security Council as involved in terrorism or the proliferation of weapons of mass destruction (UN Sanction List) or those designated by court orders.
e. The Company rejects business relationships or transactions with shell banks.
The Company requires customers to identify themselves before establishing a relationship or conducting transactions, including verifying their identity according to the Digital Asset Business Decree, regulations of the Bank of Thailand, and other relevant authorities' regulations.
(1) The Company conducts appropriate customer due diligence based on the customer's risk level for money laundering, financing of terrorism, and the proliferation of weapons of mass destruction.
(2) The Company checks customer information and beneficial owners against high-risk lists for money laundering and counter terrorism and proliferation of weapon of mass destruction financing, as well as, any future lists announced by the Anti-Money Laundering Office, including additional high-risk lists from external providers. The Company also verifies the control, supervision, and binding authority of legal entities or individuals involved in legal agreements, including identifying related persons in senior management positions.
The Company establishes appropriate measures to prevent money laundering and counter terrorism and proliferation of weapon of mass destruction financing based on a risk-based approach in line with international standards.
The Company implements measures to prevent and suppress the financing of terrorism and the proliferation of weapons of mass destruction as follows:
(1) Rejecting relationships and transactions with designated persons, including freezing assets of designated persons or those acting on their behalf or under their direction, directly or indirectly, entities controlled by designated persons, and the beneficial owners of designated persons before establishing relationships, during relationships, and after terminating relationships with current or former customers within the period specified by the Anti-Money Laundering Office (AMLO).
(2) Reporting information about suspended assets to the AMLO within the period specified by the AMLO.
(3) Reporting information about current or former customers of the Company who are on the designated persons list or who have or had transactions with such persons to the AMLO within the period specified by the AMLO.
(4) Establishing appropriate or necessary measures to prevent the financing of terrorism and the proliferation of weapons of mass destruction according to the criteria and methods prescribed by law.
The Company reports transactions as specified by the AMLO, such as suspicious or unusual transactions or any other transactions (if any).
The Company requires employees to receive adequate and continuous training on anti-money laundering and counter terrorism and proliferation of weapon of mass destruction financing, following the guidelines set by the AMLO and the Company.
The Company retains information, documents, and evidence for the period specified by law, AMLO regulations, Bank of Thailand regulations, and other relevant authorities' regulations as follows:
(1) Information, documents, and evidence of customer identification or other identification documents of customers, agents, partners, and representatives used for customer due diligence and verification.
(2) Information, documents, and evidence related to transaction reporting under anti-money laundering laws and counter-terrorism financing laws.
In cases of data sharing, guidelines, procedures, or manuals must be established on how to conduct such activities and how to maintain confidentiality during information sharing.
The Company assigns the Internal Audit Department, an independent unit, to assess the adequacy of internal controls and audit the Company's anti-money laundering and counter terrorism and proliferation of weapon of mass destruction financing operations, and report the audit results to the Audit Committee.
The Company issues policy, procedure, and manual following the guidelines or regulations of the AMLO, the Securities and Exchange Commission (SEC), the Bank of Thailand, and other relevant authorities, and regularly reviews and updates them. The Company also establishes AML/CTPF operational procedures to ensure employees can achieve the objectives of this policy and other relevant regulations.