Coinciding with the launch of Leondrino Wallet, Leondrino Exchange would like to inform its clients about the implementation of measures according to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (hereinafter AML/CFT Act). In order to support government in the fight against financing of terrorism and money laundering, the Act requires all financial institutions and related service providers to collect, verify and store identity data of persons and entities seeking to establish an account or Leondrino Wallet. Correspondingly, based on risk assessment, Leondrino Exchange has developed an internal Anti-Money Laundering Program and Counter Terrorism Financing Program (hereinafter AML Program to be aligned with the goals of the AML/CFT Act. These include:
By signing up for a Leondrino Trading Account (Leondrino Wallet including trading entitlements), you accept the following terms and conditions:
In accordance with the AML Program, Leondrino Exchange will, upon the account opening and on an ongoing basis, exercise due care in accordance with each client’s risk levels.
This means: in accordance with the Privacy Act of 1988, Leondrino Exchange will request a specified set of background information to confirm a client’s identity; store this identity-related information as well as methods and results of the identity check; inform clients that we will request information and reconcile with government-provided lists of terror suspects.
The requested information shall include:
To verify the above information, Leondrino Exchange will request the following documentation from prospective clients:
Leondrino Exchange might request additional documentation and background information. In some instances, copies of requested documents may suffice, provided they have been officially certified and appraised.
Ban of Sham Tansactions
We hereby inform customers of Leondrino Exchange regarding prohibited transactions, which are commonly called “sham transactions”. This prohibition is imposed according to the AML / CFT Act in order to identify, to defuse and manage potential risks in relation to money laundering and terrorist financing for Leondrino Exchange.
This provision requires that all orders are made in good faith for the purpose of access to and making profits from movements of quotas in financial instruments. No Customer may open up directly or indirectly opposite positions (ie buy and sell orders) in the same financial instrument, where the intention of the customer does not lie in the fact to make profit from speculative activities, but to avoid an honest, the market risk exposed market position.
It is also inadmissible, to open opposite positions in the same financial instrument for various eWallets or Leondrino trading accounts with shared beneficial ownership (this excludes accounts with less than 100% public ownership a) as well as eWallets or Leondrino trading accounts of customers who stand in any relationship to one another, if this is the intention of avoiding market risk or price competition. Such activities are also considered a violation of the sham transaction ban. The fact that there is a delay between the opening of opposite positions, does not exempt from this ban, if the performance entails a sham transaction result. The mere delay of opening a buy and sell order does not exclude, depending on the terms of the order, that orders are entirely or partially traded against each other. To the extent as orders are traded against each other, their outcome can be regarded as an illegal sham transaction, regardless of the fact that the orders were opened at different times.
In all cases where one of the above transactions is recognized, Leondrino Exchange may exercise its rights pursuant to the relevant User Agreement, which the user has explicitly agreed to as part of the account opening; including, but not limited to: cancellation or adjustment of the respective transactions of users.