Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy
KOSON PRO CORPORATION
1. Introduction and Purpose of the Policy
This Policy is developed and approved by KOSON PRO CORPORATION, a company registered in the Republic of Panama, to ensure compliance with national legislation, including Law 23 of 2015, and international standards (such as FATF recommendations), as well as supervisory requirements of the Unidad de Análisis Financiero (UAF).
KOSON PRO CORPORATION is committed to preventing the misuse of its services and infrastructure for money laundering and terrorist financing purposes.
2. Scope of Application
This Policy applies to all employees, departments, and clients of KOSON PRO CORPORATION, as well as to its operations related to:
- the provision of cryptocurrency services;
- other regulated financial or agency-based activities.
3. Legal and Regulatory Framework
KOSON PRO CORPORATION adheres to the following laws and standards:
- Law 23 of 2015 of the Republic of Panama;
- Regulatory circulars and resolutions issued by the UAF Panama;
- FATF Recommendations;
- Any other applicable local and international legal instruments.
4. Governance and Responsibility
Responsibility for the implementation of this Policy lies with the management of KOSON PRO CORPORATION and its designated compliance functions, including those responsible for client onboarding, transaction monitoring, and reporting obligations.
5. Know Your Customer (KYC)
All clients of KOSON PRO CORPORATION, whether individuals or legal entities, must undergo appropriate identification and verification procedures in accordance with internal rules and applicable UAF guidelines.
6. Risk Assessment and Profiling
KOSON PRO CORPORATION performs initial and ongoing client risk assessments. Clients are categorized as low, medium, or high risk depending on their activity, geographical location, ownership structure, and transaction volumes. Enhanced Due Diligence (EDD) is applied to high-risk clients, including PEPs and clients from high-risk jurisdictions.
7. Monitoring and Reporting
All transactions processed by KOSON PRO CORPORATION are subject to ongoing monitoring. Any suspicious activity is documented and, when necessary, reported to the UAF in accordance with applicable laws and deadlines.
8. Recordkeeping
KOSON PRO CORPORATION commits to retaining all documentation related to AML/CFT compliance — including KYC records and internal/external reports — for a minimum of eight (8) years after the end of the client relationship.
9. Staff Training
All relevant personnel of KOSON PRO CORPORATION must undergo mandatory AML/CFT training upon hiring and at least annually thereafter. The training program covers detection methods, reporting duties, and internal compliance procedures.
10. Internal Audit and Policy Review
KOSON PRO CORPORATION conducts internal audits of its AML/CFT framework at least once per year. This Policy and its underlying procedures are reviewed and updated regularly to reflect changes in law, business operations, and risk exposure.