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Bank Secrecy Act and Anti-Money Laundering Program

 

Thorex.net (referred to herein sometimes as “we” or “our”) has developed a program in compliance with the United States Bank Secrecy Act (“BSA”) and Anti-Money Laundering statutes, which exist in many countries, including without limitation the United States of America.

 

Our program is called our “BSA/AML Program,” and covers our money services business and money transferring services business. This BSA/AML Program intends to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States and other countries where our customers and depositors are located. This includes, but is not limited to:

 

  • Establishing robust internal policies, procedures and controls that strive to combat any attempted use of Thorex.net for illegal or illicit purposes, and to ensure our customers retain their basic protections under consumer protection laws;
  • Complying with applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”), and other government bank secrecy institutions;
  • Filing Suspicious Activity Reports (“SARs”);
  • Filing Currency Transaction Reports (“CTRs”);
  • Maintaining comprehensive records of orders and other transfers;
  • Employing a Chief Compliance Officer (“CCO”) who is responsible for the implementation and oversight of our BSA/AML Program;
  • Executing Know Your Customer (“KYC”) procedures on all customers (see our Know-Your-Customer Policy);
  • Performing regular, independent audits of our BSA/AML Program;
  • Following record retention requirements; and
  • Implementing a formal and ongoing compliance training program for all new and existing employees.

 

Policies and Procedures

Our BSA/AML Program has been reviewed and approved by our management. Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies.

 

Internal Controls

We have developed internal policies, procedures, and controls designed to comply with appli­cable BSA/AML laws and regulations, some of which are outlined here on this page, including without limitation our Privacy and Know-Your-Customer Policies, our Customer Identifica­tion Pro­gram (“CIP”), as well as other reporting requirements and audits required by national laws, where applicable.

 

Training

All of our employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within thirty (30) days of start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

 

Compliance Officer

Our CCO is responsible for developing and enforcing the policies and procedures of our BSA/AML Program. Our CCO is required to report any violations of our BSA/AML Program directly to our CEO and Board. In addition, our CCO is responsible for recording and filing government reporting forms, including without limitation SARs, CTRs, performing a BSA/AML Program audit annually; and where we have decided to cooperate with government agencies.

 

Customer Identification

Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

 

Account Opening Process

In order to open an account and use Thorex.net, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to use Thorex.net.

 

Individual customer — Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:

  • Email address;
  • Mobile phone number;
  • Full legal name;
  • Government identification number, including without limitation Social Security Number (if applicable);
  • Date of birth (“DOB”);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID);
  • Home address (not a mailing address or P.O. Box); and
  • Additional information or documents at the discretion of our Compliance Team.

 

Non-US customers are required to provide proof of address (e.g., a government identification card or other satisfactory evidence). If you successfully meet and complete our CIP require­ments, and do not appear on any applicable government watchlist, then we will provide you with account opening agreements electronically.

 

Institutional customer — Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:

  • Institution legal name;
  • Government corporate or other identification number issued by government chartering your institution;
  • Full legal name (of all account signatories and beneficial owners);
  • Email address (of all account signatories);
  • Mobile phone number (of all account signatories);
  • Address (principal place of business and/or other physical location);
  • Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
  • Contract information of owners, principals, and executive management (as applicable);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID) for each in­di­vi­dual beneficial owner that owns 10% or more, as well as all account signatories; and
  • Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).

 

If your institution successfully meets and completes our CIP requirements and neither it nor any of its owners, principals, executive, or managers appear on OFAC or any other govern­mental watchlist, we will provide you with account opening agreements electronically.

 

Suspicious Activity / Currency Transaction Reports

We cooperate with government investigators where appropriate, in our discretion, if we know, suspect or have reason to suspect suspicious activities have occurred on Thorex.net. A sus­picious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our CCO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify reporting to the applicable government agency.

 

In addition, all currency transactions over a determined USD value are reported to FinCEN via CTR filing. Our CCO maintains records and supporting documentation of all SARs and CTRs that have been filed.

 

Reporting Requirements

All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

 

BSA/AML Program Audit

 

Internal

The CCO is responsible for performing an audit of our BSA/AML Program at least annually, and presenting the results to our President, CEO and Board.

Independent

Our CEO oversees the performance of an independent test of our BSA/AML Program annually. The CCO is not responsible for the independent test, and the CCO’s performance is a subject of the test. Results are sent directly to Thorex.net’s audit committee.

 

As per our Privacy/Know-Your-Customer Policy, and our Terms of Use, use of our website Thorex.net constitutes consent to the terms of this BSA-BSA/AML Program.

 

All ques­tions about this BSA-BSA/AML Program should be sent to

info@thorex.net

 

End of BSA/AML Policy

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