AML Notice
This document gives an overview of the standards of the “Anti-Money Laundering” policies, thereby setting our practices for the prevention of money-laundering activities while dealing with our users.
The objective of this AML Notice is to inform the reader of how Hurricane Finance responds to its services being used, intentionally or unintentionally, by criminal elements for money-laundering activities.
To ensure bare minimum international compliance, basic AML checks are performed on the wallets that interact with our services. Receipts of AML checks are instantly destroyed and never kept.
While we may not be able to service all customers due to international AML policies, less than 0.1% of swaps fail to pass. Either way, funds are never lost or frozen.
Swaps where the sender wallet fails the necessary AML checks are automatically refunded. Unlike all other refunds, the sender must bear the transaction cost of the refund.
If the destination wallet provided in an order is known to be associated with a terrorist organization such as a state-sponsorsed hacking group, then we may block creation of that order altogether.
The only required inputs to perform the automatic AML checks on an order are the associated wallet addresses. We never use any other data when we perform an AML check.
The Policy mandates non-invasive AML efforts which in turn help us to manage the risks of our services prudently to ensure bare minimum compliance in the relevant jurisdictions and deny services to malicious users.
Hurricane Finance employs a steadfast approach in the least invasive sufficient implementation of the latest recommendations and revised guidelines by FATF, European Parliament, and regulators of the financial industry by and large.
Glossary
- AML Anti-Money Laundering
- KYC Know Your Customer
- CIP Customer Identification Program
- PEP Politically Exposed Persons
- STR Suspicious Transaction Reporting
- SAR Suspicious Activity Reporting
Summary
The Policy covers the following matters:
- CUSTOMER IDENTIFICATION PROCEDURE (CIP)
- RECORDKEEPING
- AML COMPLIANCE OFFICER
- MONITORING OF TRANSACTIONS
- RISK MANAGEMENT
CUSTOMER IDENTIFICATION PROCEDURE (CIP)
Hurricane Finance implements a non-invasive CIP that automatically infers the source of funds in the wallets associated with each order.
Hurricane Finance denies service in cases of suspicion but does not withhold services in exchange for successful identity document verification or other common KYC procedures.
RECORDKEEPING
We will NOT collect or retain records of IP address, approximate location, browser metadata, session cookies, device info, or other user data; we will retain records of live agent support interactions only for as long as strictly necessary.
AML COMPLIANCE OFFICER
The AML Compliance Officer is the person, duly authorized by Hurricane Finance, whose responsibility is to implement and effectively monitor the application and enforcement of the AML policy as outlined in this document. The AML Compliance Officer is obliged to oversee and conduct effective monitoring of all aspects of Hurricane Finance’s anti-money laundering and counter-terrorist financing. Any suspicious behavior or activities should be reported to the AML Compliance Officer.
Communication with the AML Compliance Officer in regards to this Policy is conducted via team@hurricane.finance.
MONITORING OF TRANSACTIONS
The CIP implemented by Hurricane Finance automatically infers a risk score for every relevant wallet, calculated by analyzing every inbound and outbound transaction associated with each wallet.
We have an understanding of the normal and reasonable activity of the customer, ensuring that we have the means of identifying transactions that fall outside the regular pattern of activity.
RISK MANAGEMENT
We have put in place appropriate procedures to ensure the effective implementation of the AML guidelines outlined on this page. The implementation procedure covers proper management oversight, systems and controls, segregation of duties, training, and other related matters.
From time to time, the Hurricane Finance AML Compliance Officer will carry on the necessary quality checks and file audits to ensure that the AML policies and procedures are adhered to.