Full compliance policy
AML/CFT Policy.
CGMS — Crypto Global Market Services is operated by CRYPTO GLOBAL MARKET SOLUTIONS S.R.L., a company incorporated in the Republic of Costa Rica, corporate ID (cédula jurídica) 3-102-892579, registered address: San Jose, Mata Redonda, Barrio Las Vegas, Edificio Color Azul, Diagonal al Colegio La Salle, Costa Rica.
This page publishes the full Anti-Money Laundering and Combating the Financing of Terrorism Policy for CGMS. Official contact channel: contact@cgms.io.
Anti-Money Laundering and Combating the Financing of Terrorism
Policy
CRYPTO GLOBAL MARKET SOLUTIONS S.R.L.
Last updated: July 2026
This Anti-Money Laundering and Combating the Financing of Terrorism Policy
(“AML/CFT Policy”) has been adopted by us to prevent the use of services for
money laundering and terrorist financing activities. We are committed to complying
with all applicable laws, regulations, and guidance regarding AML and CFT as
defined below.
AML/CFT Policy intends to protect Company from being used as a tool for illegal
activities such as money laundering or terrorist financing. AML/CFT Policy sets out
specific procedures to achieve this goal, including the implementation of robust client
identification process, ongoing Transaction Monitoring to detect Suspicious Activity.
By using our services via our Website, crypto exchanges or otherwise, or by using
our Website by our customer, he/she/it expressly agrees with AML/CFT Policy.
1 Definitions
1.1 The following terms has the meanings as defined below:
(a) Act means Law No. 8204, the “Law on Narcotic Drugs, Psychotropic
Substances, Unauthorized Drugs, Related Activities, Money
Laundering, and Financing of Terrorism”.
(b) AML means anti-money laundering being a set of activities, procedures
and regulations created to prevent criminal activities related to money
laundering.
(c) AML/CTF Compliance Officer means an officer or another designated
person responsible for reviewing and investigating reports of
Suspicious Activity and determining whether the reported activity is
indicative of money laundering or terrorist financing. He/she also takes
necessary steps to report Suspicious Activity to the appropriate
authorities.
(d) beneficial owner means an individual or individuals exercising direct
or indirect control over a customer through the powers they have,
which arise from legal or factual circumstances, enabling them to
exercise decisive influence over the actions or activities undertaken by
a customer or an individual or individuals on whose behalf business
relationships are established or the occasional transaction is carried
out.
(e) CFT means counter-financing terrorism being a set of activities,
procedures and regulations created to prevent criminal activities
related to terrorism.
(f) customer means you as an individual or a legal entity if you use our
services, Website.
(g) Due Diligence shall mean a thorough process of identifying and
assessing the risks associated with new relationships, which includes a
variety of steps to verify the identity of the customer, assess the risk of
money laundering or terrorist financing, and obtain information about
the customer's Source of Funds, Source of Wealth and intended use of
Company's services.
(h) Ongoing Monitoring means regularly reviewing and assessing the
activities of customers and transactions to detect Suspicious Activity
and ensure compliance with AML/CFT Policy and internal Company’s
policies and procedures.
(i) PEP (Politically exposed person) means an individual holding a
significant position or performing a significant public function.
(j) Source of Funds (SoF) means the origin of the money or assets that a
customer uses to conduct transactions or activities.
(k) Source of Wealth (SoW) means the origin of the customer’s entire
body of wealth (i.e. total assets) which explains activities the customer
participates in and their geographical location.
(l) Sanctions Lists means lists of individuals or legal entities that have
been designated by government agencies and international
organizations as being subject to sanctions, embargoes, or other
restrictions on trade or financial transactions.
(m) Suspicious Activity means any unusual or suspicious financial
transactions or activities that may indicate money laundering or terrorist
financing.
(n) Third-Party Service Providers means external companies or
individuals that provide services to Company, such as accounting,
legal, or IT services etc.
(o) Transaction means a legal or factual act on the basis of which is made
the transfer of ownership or possession of assets, funds, or a legal or
factual act made for the purpose of transferring ownership or
possession of assets, funds.
(p) Transaction Monitoring means a process of reviewing and analyzing
transactions to detect Suspicious Activity and ensure compliance with
AML/CFT policies and internal Company’s policies and procedures.
(q) Website means https://cgms.io/ and/or another website of
Company, as we may operate from time to time.
2 Who we are?
2.1 We are CRYPTO GLOBAL MARKET SOLUTIONS S.R.L., a company
registered under the laws of the Costa Rica with company number
3-102-892579 and a registered address at San Jose, Mata Redonda, Barrio
Las Vegas, Edificio Color Azul, Diagonal al Colegio La Salle, Costa Rica
(“Company,” “we,” “us,” or “our”).
2.2 The Company provides services through direct communication with
customers who wish to use its cryptocurrency exchange services and have
contacted the company via the email address listed on its website or have
otherwise learned about the Company.
2.3 The Company does not provide services of exchange of fiat currency for
another fiat currency and payment services.
3 When are we obliged to make appropriate Due Diligence,
financial security measures prescribed by Act?
3.1 When
(a) establishing economic relations (showing the characteristic of
permanence);
(b) conducting an occasional transaction with the use of cryptoassets of
the equivalent of an amount exceeding the company's thresholds;
(c) see suspected money laundering or terrorist financing;
(d) have doubts about the veracity or completeness of customer
identification data obtained to date;
(e) in other cases prescribed by Act.
4 When do we conduct simplified or enhanced Due Diligence,
financial security measures?
4.1 Simplified financial security measures are allowed where a risk assessment
confirms a lower risk of money laundering or terrorist financing.
4.2 We draw your attention that the lower risk may be evidenced by the fact that a
customer is:
(a) a resident of a member state of the European Union, a member state
of EFTA - a party to the EEA Agreement;
(b) a resident of a third country described by reliable sources as a country
with low levels of corruption or other criminal activity;
(c) a resident of a third country where AML/CFT regulations are in force,
according to reliable sources;
(d) another low risk person defined as such by Act or appropriate
governmental authorities.
4.3 Enhanced security measures are applied in case of a higher risk of money
laundering or terrorist financing and, in particular, in case of customers
coming from or based in a high-risk third country. For enhanced Due Diligence
details, please see the terms and conditions below.
4.4 The criteria of customers for the enhanced security measures are defined by
internal AML/CFT policies and regulations of Company, Act or appropriate
governmental authorities.
5 What are we obliged to collect from you as a customer for
identification and verification? Know-your-Customer (KYC)
procedures.
5.1 In the case of an individual:
(a) name and surname, date of birth;
(b) residency, citizenship;
(c) the tax number, and if no tax number has been assigned, the date of
birth and country of birth;
(d) the series and number of the person's identification document;
(e) address of residence;
(f) where the customer is a sole proprietor, in addition to the above, also
collect the following:
(i) customer's full business name (if any) under which the customer
carries on his or her business;
(ii) full address of the customer's principal place of business (if any);
(or the customer's residential address);
(iii) any business number issued to the customer;
(iv) tax identification number;
(g) other information needed for the identification and verification of a
customer, as required by Act, our Company’s internal documentations.
5.2 Please note that we could ask you to provide copies of documents, fill in the
forms, and questionnaires as required by us, and you are obliged to provide
them all.
5.3 In the case of legal entities or organizational unit without legal personality:
(a) the full name of the company as registered at the company registry;
(b) organizational form;
(c) the full address of a company's registered office;
(d) the full address of a company's principal place of business, if any;
(e) Tax Identification Number, and in the absence of such a number - the
country of registration, the name of the relevant registry, and the
number and date of registration;
(f) the name of each director of the company;
(g) identification data of the person representing that legal entity or
organizational unit without legal personality;
(h) identification of beneficial owner (his/her name, data itemized abode,
other information);
(i) other information needed for the identification and verification of a
customer, as required by Act, our internal documentations.
5.4 Company could decide to provide Enhanced Due Diligence, if it becomes
aware that:
(a) it determines under its risk-based systems and controls that the money
laundering, terrorist financing risk is high;
(b) a reasonable suspicion has arisen in relation to the customer or
transaction;
(c) a party to a transaction or proposed transaction is physically present in,
or is a corporation incorporated or doing business in, a jurisdiction
deemed high-risk;
(d) a service is being provided to a customer who is, or who has a
beneficial owner who is, a PEP;
(e) it has determined that there is a significant change in the nature of a
customer’s business relationship, its control structure or its beneficial
ownership.
5.5 Where Enhanced Due Diligence is applied, Company could undertake one or
more of the following actions:
(a) clarify or update KYC information already collected from the customer;
(b) obtain further KYC information, including, where appropriate, taking
reasonable measures to identify the Source of Funds, Source of
Wealth, and the ultimate beneficial ownership of the customer (if not an
individual);
(c) clarify the nature of the customer’s ongoing business with Company;
(d) consider any suspicion that may have arisen for the purposes of
submitting a suspicious matter report; or
(e) ask additional documents, information.
5.6 The Сompany conducts identification of the customer and verification of his,
her identity, including in particular whether he, she is PEP, PEP’s close
associate, or PEP's family member. Any customer relationship with a PEP will
be deemed high-risk. Determination of whether a customer is PEP is made by
the customer's declaration before using our services and ongoing checking of
the information obtained to identify and verify the person. The customer shall
make a declaration that he/she is not a person holding such a position.
5.7 Information and documents provided by a customer must be accurate and
up-to-date.
5.8 Verification consists in confirming the established identification data of the
persons mentioned above, based on documents required by us.
5.9 The Company reserves the right to request photo/video verification of the
customer, its representatives etc. In turn, the Company verifies the
authenticity of documents and information provided by the customer.
5.10 If a customer's identification information has been altered or their activity
appears suspicious, Company has the right to request updated documents
from the customer, even if they have already been verified.
5.11 Additionally Company might also assess the risk of money laundering or
terrorist financing by researching the customer's background, including
financial history, and by evaluating the industry or sector, obtains information
about the customer’s Source of Funds, Source of Wealth and intended use of
Company's services to understand business activities.
6 Do we conduct Ongoing Monitoring?
6.1 Yes, we do. The Company recognizes the importance of Ongoing Monitoring
to ensure that customers do not pose a risk of money laundering or terrorist
financing. Therefore, it conducts Ongoing Monitoring of customers to ensure
that their activities do not change and become a higher risk. This includes
Transaction Monitoring for Suspicious Activity, reviewing a customer’s
information for any changes, and conducting additional Due Diligence when
necessary.
6.2 Overall, Company's Due diligence process and ongoing monitoring are
essential tools for identifying and managing the risks associated with its
external relationships and for ensuring that it is complying with applicable laws
and regulations related to AML and CFT.
6.3 Ongoing Monitoring of the customer's business relationships, including:
(a) analysis of transactions carried out within the framework of the
business relationship to ensure that these transactions are consistent
with our knowledge of the customer, the type and scope of its business,
and consistent with the money laundering and terrorist financing risks
associated with that customer;
(b) investigation of Source of Funds, Source of Wealth, assets, funds at
the disposal of the customer - in cases justified by the circumstances;
(c) ensuring that the documents, data or information in its possession
regarding business relations are kept up to date.
7 Sanctions screening
7.1 The Company has a responsibility to ensure that it is not doing business with
individuals and legal entities that are prohibited by sanctions laws. To achieve
this, the Company implements procedures to screen all customers against
Sanctions Lists. This will include checking the names of individuals and legal
entities against lists of individuals and legal entities that have been designated
by government agencies, international organizations as being subject to
sanctions, embargoes, or other restrictions on trade or financial transactions.
7.2 The Company also screens transactions to ensure that they do not involve
prohibited individuals or legal entities. This will involve reviewing transaction
details, such as the names of parties involved, the amounts, and the location
of the transaction, to ensure that they are not connected to any individual or
legal entity that is subject to sanctions.
7.3 Additionally, Company has procedures in place to investigate and report any
potential sanctions violations to the appropriate authorities.
8 Risk Assessment
8.1 The Company conducts a comprehensive risk assessment of the relationships
with customers to identify and evaluate any potential risks. This risk
assessment considers a range of factors, including the nature of the
relationship, the location of the customer, the customer's industry or sector
etc.
8.2 Based on the results of the risk assessment, Company takes appropriate
measures to mitigate any risks identified.
8.3 Additionally, the Company implements a risk-based approach for its AML/CFT
compliance documents.
8.4 Company may provide services to customers who/which have a connection
with foreign jurisdictions. In assessing the risk associated with a jurisdiction to
which a customer is connected, Company takes account of the following
classifications:
(a) Financial Action Task Force (FATF) member countries;
(b) non-FATF countries whose regimes are not subject to sanctions
imposed by the UNSC and are not otherwise deemed as high-risk
jurisdictions or prescribed foreign countries below;
(c) countries with AML/CTF deficiencies, serious organized crime, political
instability, corruption and weak rule of law;
(d) countries subject to UNSC sanctions.
9 Reporting Suspicious Activity
9.1 The Company recognizes the importance of having a process in place to
report any suspicious activities or transactions that indicate money laundering
or terrorist financing.
9.2 Reports of suspicious activities will be reviewed and investigated by the
designated person at the Company, which will be responsible for determining
whether the reported activity is indicative of money laundering or terrorist
financing. If it is determined that the reported activity is suspicious, the
designated person at the Company will take the necessary steps to report the
Suspicious Activity to the appropriate authorities.
10 Third-Party Service Providers
10.1 The Company takes steps to ensure that Third-Party Service Providers
comply with its AML/CFT regulatory requirements. This will involve conducting
thorough Due Diligence on these providers, reviewing their reputation and
past behavior, and evaluating their own AML and CFT policies and
procedures. To ensure Sanctions compliance, Company could include specific
provisions related to AML and CFT in agreements with Third-Party Service
Providers. Additionally, Company conducts regular monitoring of these
providers to confirm they are adhering to the AML and CFT requirements set
forth in the contract.
11 Specific restrictive measures
11.1 Customers’ Transaction Monitoring and analysis of the received data is one of
the tools for assessing the risk and detecting suspicious transactions. In case
of suspicion of money laundering or terrorist financing, Company controls all
transactions and reserves the right to:
(a) suspend providing services and freeze, block assets, funds until the
circumstances are clarified;
(b) return the customer's assets, funds by canceling the order, instruction;
(c) take other actions allowed by Act, Company’s internal policies and
procedures.
12 Conclusion
12.1 The Company is committed to complying with all applicable laws and
regulations related to AML and CFT in its external relationships. By
implementing this AML/CFT Policy, the Company aims to prevent its services
from being used for money laundering or terrorist financing activities. The
Company will review and update this AML/CFT Policy regularly to ensure that
it remains effective in addressing the risks of money laundering and terrorist
financing.
12.2 The Company is required to document the financial security measures in
place. Records are kept for a period of 5 years from the date of termination of
business relations with the customer or from the date of the occasional
transaction, unless a longer term is prescribed by Act. Documents are stored
in a manner that ensures their security and in accordance with data protection
regulations.
12.3 If You have any questions about AML/CFT questions you can contact us:
contact@cgms.io