CoinList is not available to residents of
CoinList is not available to residents of the following U.S States:
State
|
License
|
State Agency
|
---|---|---|
Delaware | Sale of Checks and Transmission of Money, 027874 |
Office of the State Bank Commissioner
555 E. Loockerman Street, Suite 210 Dover, DE 19901 |
District of Columbia | Money Transmitter License, MTR1785267 |
Department of Insurance, Securities, and Banking
810 First Street, NE, Suite 701 Washington, District of Columbia 20002 |
Florida | Money Transmitters Part II, FT230000254 |
Florida Office of Financial Regulation
200 E. Gaines Street Tallahassee, FL 32399 |
Illinois | Money Transmitter License, MT.0000351 |
Illinois Department of Financial and Professional Regulation
Consumer Credit Section 100 West Randolph Street 9-100 Chicago, IL 60601 |
New Jersey | Money Transmitter License, 1903903C22 |
New Jersey Department of Banking and Insurance
20 West State Street, PO Box 325 Trenton, NJ 08625 |
Puerto Rico | Money Transmitter License, TM-122 |
Office of the Commissioner of Financial Institutions
1492 Ave. Ponce De León Suite 600 Centro Europa Building Santurce, Puerto Rico |
Texas | Texas MTL No. 3206 |
Texas Department of Banking
2601 North Lamar Boulevard Austin, Texas 787705 |
Vermont | Money Transmitter License, 100-154 |
Department of Financial Regulation
Consumer Services 89 Main Street, Montpelier, VT 05620 - 3101 |
Washington | Money Transmitter License: 550-MT-127592 |
State of Washington - Department of Financial Institutions
Division of Consumer Services 150 Israel Road, S.W., Tumwater, WA 98501 |
Last updated: November 12, 2020
Bank Secrecy Act and Anti-Money Laundering Compliance Program
Welcome to the CoinList digital asset platform. The platform is owned and operated by CoinList Markets LLC (“we,” “us” or “our”). We have developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States and other countries where we conduct business. This includes, but is not limited to:
Our BSA/AML Program has been reviewed and approved by our Managers. Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. We are regulated by the US state departments of financial institutions identified in the “Licenses” section of this webpage and our BSA/AML Program is subject to their review and approval.
Internal ControlsWe have developed robust 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, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.
TrainingOur 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, and all new employees receive training, to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. All documentation related to compliance training including materials and attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.
Compliance OfficerOur 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 our Managers. In addition, our CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.
Customer IdentificationOur 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.
In order to open an account and use the platform, 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 our platform.
If you successfully meet and complete our CIP requirements, we will complete your account onboarding.
If your institution successfully meets and completes our CIP requirements, we will complete your account onboarding.
Over the course of your customer experience on the platform, our team may reach out to you for additional information in order to ensure the safety and integrity of our customer base and our trading platform, and as required for ongoing compliance with our regulatory obligations. Please be aware that your failure to comply with these requests may result in restrictions on your account.
Suspicious Activity / Currency Transaction Reports ProcessWe file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on our platform. 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 the filing of a SAR.
In addition, all currency transactions over a determined USD value are reported to FinCEN via a CTR filing.
Our CCO maintains records and supporting documentation of all SARs and CTRs that have been filed.
Reporting RequirementsAll 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