Anti-Money Laundering Policy
Troika IO, Inc and Troika Media Group (collectively “Company” or "Troika") are incorporated under the laws of the State of California and offer services through an internet-enabled peer-to-peer (“P2P”) marketplace for the purchase and sale of digital assets, including but not limited to non-fungible tokens ("NFTs").
NFTs range from digital artwork, gift cards, digital collectibles, fan tokens, virtual real estate, to an entry ticket for a virtual event. NFTs are “minted” by issuers or creators and purchased through online exchanges or marketplaces like those being created by Troika and its subsidiaries. This is the Anti-Money Laundering and Counter-Terrorist Financing Program for Troika IO.
The Company is not registered as a Money Services Business with the United States Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”), however Troika's Anti-Money Laundering (“AML”) policies and procedures are designed to deter illicit activities on the platform, protect the users, the business, and the digital currencies and financial services communities from exploitation by criminals. The Company is compliant with the requirements of the Bank Secrecy Act and related FinCEN regulations and guidance.
As part of Troika's Compliance policies, Know Your Customer (“KYC”) policies and procedures for individual and institutional customers have been designed to enable the Company to form a reasonable belief that it knows the true identity of those of its customers for which such review has been performed. The policy applies to all users on the platform and is followed by all of the Company’s employees, consultants, officers, owners and directors.
Using a risk based approach as part of KYC & AML Compliance, Troika has taken the following measures:
- Appointment of a Chief Compliance Officer who has the sufficient level of expertise and independence, has responsibility for the oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
- Establishing and maintaining risk-based KYC, Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) Policy;
- Establishing risk-based tiers for verification of the Company's users;
- Cooperation with law enforcement requests and local regulatory requirements;
- Decentralized Autonomous Organizations ("DAO");
- Filing of Suspicious Activity Reports (“SARs”);
- Company-wide BSA/AML/OFAC training;
- Ongoing rule based transaction monitoring;
- Investigations using blockchain analytics;
- Continued crypto education ("Docs")
- Use of various anti-fraud systems;
We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on our platform. A suspicious transaction is often one that is inconsistent with a user’s known and legitimate business, personal activities or personal means. Our Chief Compliance Officer reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR. Our Chief Compliance Officer maintains records and supporting documentation of all SARs that have been filed.
The Company has also adopted ongoing OFAC sanctions policies and procedures designed to protect the platform from being used for prohibited transactions, by sanctioned individuals or for the purposes of evading, avoiding or otherwise circumventing U.S. and global sanctions.
Troika fully cooperates with all OFAC, Specially Designated Nationals (SDN) and Blocked persons sanctions lists. Please refer to Banned Countries for a list of the banned countries that are prevented from using Troika's platform.
Troika is engage in cryptocurrency services that include the buying, selling and trading of Bitcoin, Ethereum, stablecoins, non-fungible tokens (NFTs) and other digital assets and services;
Troika's AML compliance program has not been approved by the board, but it has been reviewed by a senior committee;
Troika has taken the measures to ensure developed written procedures and supporting processes to prevent, detect, and report suspicious customer/merchant activity;
Troika has an internal audit function or other independent third party that assesses AML policies and practices on a regular basis;
Troika is prohibited doing business with shell banks. Troika has specific policies and procedures in place for the opening of accounts for Politically Exposed Persons (PEPs);
Troika has a record retention policies and procedures that comply with local laws/regulations;
Troika's AML policies and procedures applied to all of its branches and subsidiaries regardless of the country in which they operate;
Troika conduct an enterprise AML risk assessment to identify risks associated with our customers, products, services, and geographic locations;
Troika has implemented customer identification policies and procedures that are in line with local laws/regulations;
Troika does not conduct fiat deposits or withdrawals for customers, however, we still require customer identification, verification and KYC policies to protect our P2P marketplace from abuse;
If required by local laws/regulations, Troika will obtain and verify customer's ultimate beneficial ownership (UBO) information;
Troika has process to review, and where appropriate, update, the KYC policies and information for high-risk clients;
Troika assesses its customers' AML policies and practices, when applicable;
Troika screens customers against global and domestic sanctions lists, which can be found on the Banned Countries list. Troika works with third-party vendors Civic Technologies and Persona Identities Inc for identify verification.
Troika complete a risk based assessment to understand the normal and expected nature of transactions of its customers and merchants;
Troika has a transaction monitoring program designed to identify and freeze unusual or suspicious transaction activity;
Where cash transaction reporting is mandatory, Troika has procedures to identify transactions structured to avoid such obligations;
Troika retains records of its training sessions including attendance records and relevant training materials;
Troika communicates new AML related laws or changes to existing AML related policies or practices to relevant employees;
Troika does not outsource any of its compliance processes/function or key business operations to any third party agent or entity;
Troika provides adequate training, oversight and monitoring to ensure the outsourcing agent/entity complies with all necessary aspects of its AML program and provides training to relevant employees that includes identification and reporting of transactions that must be reported to government authorities, examples of red flags of money laundering involving the company's products and/or services, and internal policies to prevent money laundering;
This document was drafted and certified collectively by the Chief Compliance Officer and Head of Digital Assets, Troika IO, and Chief Operations Officer (COO), Troika Media Group ("TMG").