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Draft — not in force

This document is a working draft. It has not been reviewed by counsel and does not yet bind either party. It is published here so that the structure and the substantive restrictions can be reviewed, not so that it can be relied upon.

Our legal documents are published in English. A reviewed translation will follow once the authoritative text is settled with counsel. If anything here is unclear, please ask us before you proceed.

Anti-money-laundering statement

P2P Broker

This is a summary. Our full AML/CFT policy and onboarding procedure are provided to banks, partner service providers and supervisory authorities on request, at lukar@paxa.media.

Our position

P2P Broker connects people who want to exchange euro and crypto-assets — with each other, or with a licensed provider. It is not a registered crypto-asset service provider and it does not hold, escrow or transmit client money or crypto-assets at any point. Every exchange settles directly between two individuals whose identities we have both verified. We are not a party to it and we hold nothing.

The checks described here are carried out by two individuals appointed under our AML/CFT policy, who make the introductions. The website itself is operated by Paxa Media j.d.o.o., which provides the software and is responsible for the security of your data — it plays no part in any exchange. A dedicated Montenegrin company holding its own registration is intended and is not yet incorporated.

Identification

Montenegrin law requires identification for crypto-asset transactions above €1,000. We identify and verify every client at every amount. A published threshold is also an instruction on how to structure beneath it, and we would rather not provide one. Related transactions are aggregated, and deliberate splitting is itself a matter we escalate.

Screening

Every client is screened against United Nations, European Union, OFAC, UK OFSI and Montenegrin national sanctions lists, for politically exposed person status, and for adverse media — at onboarding and again before every introduction. Where crypto-assets are involved, the wallet addresses are screened using blockchain analytics. A confirmed sanctions match stops the process immediately.

Source of funds

Above €15,000, and in any case where something requires it, we ask for documented evidence of where the funds came from and how the wealth was accumulated. We assess whether the explanation is plausible, and we record that assessment. A document alone is not an answer.

Reporting officer

An appointed Money Laundering Reporting Officerholds that role, with a Deputy who acts in the Officer’s absence with full authority. Both are named in our AML/CFT policy and are disclosed to counsel, to our bank and to the authorities on request; we do not publish them here. The Reporting Officer has authority to refuse or end any client relationship and to make external reports, and that decision cannot be overruled. Every escalation is seen by both of them, so no decision to proceed rests on one person’s judgement alone.

Reporting, and what we cannot tell you

Where we form a suspicion, we report it to the financial intelligence unit. We are prohibited by law from telling you that a report has been made or is being considered. If we decline to proceed and do not explain why, that silence carries no implication in either direction — we apply the same wording to every refusal precisely so that it does not.

Records

Client files, verification evidence, screening results, decisions and communications are retained for five years, encrypted, with access restricted to named individuals and every access logged.

Training and review

Everyone making introductions completes anti-money-laundering training before any client contact and at least annually thereafter, and the programme is reviewed at least once a year.