Bank Secrecy Act and Anti-Money Laundering Policy

Customer Acceptance

  1. Sign Up. In order to create an account, a user must sign up by submitting their first and last name, email, agreeing to the terms of use and privacy policy.
  2. Email Confirmation. An email containing a confirmation code is sent to the user's email address. The code must be entered on the following page.
  3. Promotional Code. A user may enter a promotional code sent by the referred member.
  4. Password. The user must select a password. The password must be at least 8 characters long and contain at least one uppercase letter, one lowercase letter, one number, and one special character.
  5. Country. The user must select which country they are from. If the user is from the US, a state must be selected.
  6. Two-Factor Authentication. The user must enter a phone number that he or she wishes to use for two-factor authentication. This is usually a mobile number, and the user may have the option to select SMS or voice. Once the phone number is submitted, a confirmation is sent to the user via text message. Once the number is verified, the user may select their preferred authentication method - either by phone call or google authenticator.

Customer Identification

  1. In order to make a successful borrow transaction, the customer must upload a legible photo of his or her government-issued ID. The customer must also upload a photo of his or her face, along with the ID as well as a piece of paper with 'xCoins' and the current date written on it.
  2. The location of the customer is identified by IP address. The location of the IP address is compared with the address on the ID and the submitted billing address during checkout of a transaction. If residential IP address appears to have a risk score of above 90, the user will not be approved.
  3. A valid mobile phone number must also be entered. Voice Over Internet Protocols are not accepted. The individual registered under the mobile number will also be taken into account.
  4. The name on the xCoins account must match the name on the Paypal account or the name related to the billing information of the credit or debit card used. If there is a discrepancy between the customer submitted information on the account and the payment details, the system flags the transaction for manual approval. We then seek out further information from the customer by reaching them via phone to receive a verbal authorization before manually approving the transaction. When the customer is unable to be reached via phone call, an email is sent to the customer to notify him or her of a temporary block on the account until the customer is able to verbally verify the transaction. The customer is given 24 hours to respond, or the system will automatically decline the transaction.

Risk Management

  1. An account must be opened in the name that matches the name on the government-issued ID that is required for the verification process.
  2. The login name must be a working email address, and is verified by sending a code to make sure it is valid and the customer has access to the email address.
  3. When approving a new account, we cross verify the identity of the customer using all of the information submitted to ensure there are not any duplicate accounts or fraudulent accounts being recreated. This includes, but is not limited to, the name on the account, mobile number, government-issued ID information, uploaded photos of the customer, hand writing, IP address, payment billing information, and Paypal email information.
  4. When a customer's first borrow transaction gets approved, xCoins will reach out via phone call and verify that he or she authorized the transaction. If the customer cannot be reached via phone, an email is sent to inform the customer that the account has been temporarily disabled.
  5. xCoins requests the customer to contact us via phone and confirm that he or she authorized the last transaction on the account.

Closure

  1. When the customer is unable to provide accurate and necessary details about a transaction or account, the account will be disabled for reasons of suspicion and/or fraudulent activity.
  2. When a customer requests closure of his or her account, it is done as soon as it is brought to xCoins' attention, no questions asked.
  3. When a customer reports any fraudulent activity or unauthorized transactions on his or her account, the account is immediately disabled.
  4. When a customer creates a chargeback on a transaction that was completed successfully, xCoins is immediately notified and the account becomes disabled.

Suspicious Activity

If we have reason to suspect suspicious activities on xCoins, our compliance officer will investigate the account and file a SAR when appropriate. Any transactions over a certain USD value will be reported and filed with FinCEN. We retain all records of any reports that have been filed.

Reporting Requirements

All records are retained and are available upon official request by an applicable regulator or law enforcement agency.



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