Compliance & Commitment

•DragonXMiner complies with all applicable laws and regulations in each jurisdiction in which it operates.

•Registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN), the anti-money laundering arm of the U.S. Department of Treasury, DragonXMiner is licensed to engage in money transmission in most U.S. jurisdictions.

•DragonXMiner is required to comply with a number of financial services and consumer protection laws, including:

•The Bank Secrecy Act, which requires DragonXMiner to verify customer identities, maintain records of currency transactions, and report certain transactions.

•The U.S.A. Patriot Act (the PATRIOT Act), which requires DragonXMiner to designate a compliance officer to ensure compliance with all applicable laws, create procedures and controls to ensure compliance, conduct training, and periodically review its Risk Assessment, BSA Secrecy Act (BSA) / Anti-Money Laundering (AML) Program, and other related compliance policies and procedures (collectively, the AML Program).

Anti-Money Laundering Program

•DragonXMiner participates in an Anti-Money Laundering Program (AML). Learn more about the goals, objectives, and policy of DragonXMiner’ AML Program (Link)

•Anti-Money Laundering Program(Linked Page Content): The objectives of DragonXMiner’ AML Program include:

•Compliance as a Virtual Currency Exchanger and Money Services Business (MSB) under the BSA and the economic sanctions laws and regulations administered by the appropriate covered jurisdiction.

•Deter individuals and entities from using DragonXMiner to launder the proceeds of illegal activities.

• Cooperate with law enforcement to the fullest extent permitted by law and regulation.

•Provide employees and consultants with guidance on the actions that should be taken to comply with DragonXMiner’s legal obligations.

•Manage and mitigate money laundering and terrorist financing-related risks, including compliance risk, operational risk, reputation risk and strategic risk.

• It is the policy of DragonXMiner to performs the following:

• Comply with the requirements of the BSA and relevant sanctions laws and regulations (e.g., OFAC), and the AML Program.

•Comply with the AML regulations of DragonXMiner’s state and federal regulators.

• Maintain a written risk-based AML Program reasonably designed to: 1) comply with the record-keeping, reporting and other requirements of the BSA and its implementing regulations and the regulations of DragonXMiner’s federal and state regulators; and 2) detect, deter and report actual or suspected violations of the BSA or other illicit activity. The AML Program provides for:

  • internal controls to assure daily adherence to the AML Program
  • independent testing of the AML Program at least annually
  • designation of a qualified person as the BSA Officer

• General AML training on a regular basis for all designated personnel, and targeted training for specific business departments tailored to their risk profile.

• Implement a risk-based Know Your Customer (KYC) and Customer Due Diligence (CDD) to enable Charon to know its customers and understand their financial dealings

•Establish and implement an appropriate KYC Program for conducting both initial and ongoing due diligence on all customers, including any enhanced due diligence procedures required by applicable law

• Refuse to enter into any relationships with a prospective customer who appears on an economic sanctions list or any other applicable official government lists of prohibited persons (e.g., list of entities subject to special measures under Section 311 of the PATRIOT Act);

• Refuse to enter into any relationship with a prospective customer or any other person who fails to provide identification or other information required by the BSA or by DragonXMiner’s KYC Program, and refuse to enter into any relationship or conduct any transaction for a customer or prospective customer who provides false, inconsistent or conflicting information where the inconsistency or conflict cannot be resolved after reasonable inquiry;

• Monitor transactions and relationships according to established criteria and remain alert to potentially suspicious activity;

• Comply with the suspicious activity reporting requirements of the BSA by filing, on a timely basis, a complete and accurate Suspicious Activity Report (SAR)

•Cooperation with law enforcement authorities, federal and state regulators, other regulators, U.S. and non-U.S. government officials and other financial institutions within the parameters of applicable law; and

•Reporting to DragonXMiner’s management, as necessary but at a minimum on an annual basis, regarding the operation of the AML Program including: (1) the results of any internal or external reviews; (2) potential AML violations or deficiencies identified and the corrective actions taken or planned to address such deficiencies; (3) SAR trends; (4) any significant changes in applicable law; and (5) any significant changes in DragonXMiner’s AML risk profile.

Risk Assessment Approach

•DragonXMiner conducted a risk assessment to understand its potential money laundering and terrorist financing risks. The risk assessment took into account DragonXMiner’ customer base, the products and services offered by DragonXMiner, and the geographies in which DragonX conducts business. The results of the risk assessment were used in developing the AML Program and supporting policies and procedures.

•As part of DragonX’s commitment to ongoing enhancements to the AML Program, the Risk Assessment will be updated periodically by the designated Bank Secrecy Act (“BSA”) Compliance Officer and the AML Program will be revised as necessary to reflect changes to DragonXMiner’s AML risk profile.