1. Overview
This Anti-Money Laundering (AML) Policy outlines the measures implemented by Tradeview Financial Markets S.A.C. (operating under the YimmiT brand) to prevent, detect, and mitigate money laundering, terrorist financing, and other financial crimes. YimmiT is committed to maintaining a robust compliance framework in accordance with applicable laws and regulatory expectations in Peru, including guidance from the Unidad de Inteligencia Financiera del Perú.
2. Scope of Application
This Policy applies to all users of the YimmiT platform and covers: customer onboarding and verification; digital asset custody and transactions; ongoing monitoring and risk assessment; and internal compliance and escalation procedures.
3. Customer Identification and Verification (KYC)
YimmiT requires all users to complete identity verification prior to accessing core platform features. Verification includes: full legal name; date of birth; residential address; government-issued identification; and biometric or liveness verification. Identity verification is conducted using third-party providers, including Sumsub. YimmiT reserves the right to request additional documentation at any time and to deny or restrict access where verification requirements are not satisfactorily completed.
4. Risk-Based Approach
YimmiT applies a risk-based approach to onboarding and monitoring. Users are classified into risk categories based on factors including: geographic location; transaction behavior; volume and frequency of activity; and source of funds or wealth. Higher-risk users may be subject to enhanced due diligence measures and increased monitoring.
5. Transaction Monitoring
YimmiT monitors user activity on an ongoing and risk-based basis to detect suspicious or unusual behavior. Monitoring includes: transaction size and frequency; rapid movement of funds; conversion patterns; and wallet activity and external transfers. Blockchain analytics tools, including Elliptic, are used to assess wallet risk and identify exposure to illicit activity. Monitoring may result in automated alerts and manual review of user activity.
6. Sanctions and Screening
YimmiT conducts screening against international sanctions and watchlists, including: United Nations sanctions lists; OFAC and other international sanctions databases; and Politically Exposed Persons (PEP) screening. Users identified as sanctioned or high risk may be restricted, suspended, or denied access.
7. Source of Funds and Enhanced Due Diligence
YimmiT may request information regarding the source of funds or source of wealth, particularly where activity exceeds defined thresholds or presents elevated risk. Enhanced Due Diligence (EDD) measures may include: additional identity verification; supporting financial documentation; and ongoing monitoring and review. Failure to provide requested information may result in account restrictions, suspension, or termination.
8. Suspicious Activity Monitoring and Reporting
YimmiT maintains internal procedures to identify, assess, and escalate suspicious or unusual activity. Where activity is identified as potentially suspicious, YimmiT may: conduct internal investigations; request additional information or documentation; restrict, suspend, or terminate accounts; and implement appropriate risk mitigation measures. Where appropriate, such activity may be reported to competent authorities, including the Unidad de Inteligencia Financiera del Perú, in accordance with applicable laws and regulatory expectations. YimmiT reserves full discretion in determining the appropriate course of action in each case.
9. Custody and Asset Controls
YimmiT implements internal controls to safeguard digital assets, including: controlled and restricted access to custodial wallets; segregation and tracking of client assets; multi-layer authorization for asset movements; and continuous monitoring of wallet activity. These controls are designed to reduce the risk of unauthorized access, misuse, or financial crime.
10. Record Keeping
YimmiT maintains records related to: customer identification and verification; transaction history; risk assessments and classifications; and compliance reviews and internal decisions. Records are retained in accordance with applicable regulatory expectations and industry standards.
11. Ongoing Compliance and Review
YimmiT regularly reviews and updates its AML policies and procedures to reflect: changes in regulatory expectations; evolving financial crime risks; and enhancements to monitoring and compliance systems.
12. User Responsibilities
By using the platform, users agree to: provide accurate and truthful information; comply with applicable laws and regulations; and respond to compliance-related requests. Failure to comply may result in restriction, suspension, or termination of access.
13. Contact
For AML or compliance-related inquiries, please contact us at compliance@yimmit.com.