1. Introduction and Policy Statement
1.1 General Statement
NEXDAO LIMITED (the “Company”) adopts a zero-tolerance approach towards Money Laundering (ML) and Terrorist Financing (TF). The Company is committed to full compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong and relevant guidelines issued by the Joint Financial Intelligence Unit (JFIU).
1.2 Business Nature and Scope
The Company primarily provides B2B financial technology infrastructure and technology consulting services. Although the Company does not hold client funds on a custodial basis, it recognizes the inherent risks within the fintech sector.
This policy applies to all officers, employees, and agents of the Company.
2. Compliance Structure
2.1 Money Laundering Reporting Officer (MLRO)
The Company shall appoint a Money Laundering Reporting Officer (MLRO) with sufficient seniority. The MLRO is responsible for overseeing AML/CTF compliance, receiving internal suspicious transaction reports, and making external reports to the JFIU where appropriate.
3. Risk-Based Approach
3.1 Risk Assessment Framework
The Company applies a Risk-Based Approach (RBA) to identify and assess ML/TF risks associated with customers, jurisdictions, products, and delivery channels.
3.2 Risk Classification
Low Risk
- Public bodies or listed companies in FATF member jurisdictions
- Clients using technical consulting services only, without payment integration
Medium Risk
- Private companies (SMEs) incorporated in Hong Kong or comparable jurisdictions
- Clients using the Company’s infrastructure for non-financial applications
High Risk
- Clients incorporated in tax havens with opaque ownership structures
- Politically Exposed Persons (PEPs)
- Clients involved in virtual assets, gaming, or cash-intensive industries
4. Customer Due Diligence (CDD / KYC)
Given the Company’s B2B nature, Know Your Business (KYB) procedures are essential.
4.1 Identification of Corporate Customers
- Certificate of Incorporation and Business Registration
- Memorandum and Articles of Association
- Ownership structure chart
- Identification of directors and authorized signatories
- Proof of business activities
4.2 Identification of Ultimate Beneficial Owners
The Company shall identify and verify any natural person who ultimately owns or controls 25% or more of the corporate customer.
4.3 Enhanced Due Diligence
- Senior management approval prior to onboarding
- Establish source of wealth and source of funds
- More frequent ongoing monitoring
4.4 Sanctions Screening
All customers and UBOs shall be screened against applicable sanctions lists. The Company shall not conduct business with sanctioned entities.
5. Transaction and Ongoing Monitoring
5.1 Ongoing Monitoring
Customer information shall be reviewed on an ongoing basis. High-risk customers are subject to annual reviews.
5.2 Monitoring of Service Fee Payments
- Third-party payments unrelated to the client
- Cryptocurrency payments subject to wallet screening (if applicable)
6. Suspicious Transaction Reporting
6.1 Reporting Obligation
Any employee who knows or suspects criminal or terrorist property must report immediately to the MLRO.
6.2 Reporting to JFIU
Where suspicion is confirmed, the MLRO shall file a Suspicious Transaction Report (STR) with the JFIU via the STREAMS system.
6.3 Prohibition of Tipping-Off
Disclosure of a report or investigation to any person constitutes a criminal offense.
7. Record Keeping
All CDD and transaction records shall be retained for at least five (5) years after the end of the business relationship or transaction date.
8. Staff Training
The Company shall provide regular AML/CTF training to ensure staff understand their legal obligations and internal policies.
