Government policy and money laundering and terrorist financing risk management
Reflex Token SRL
Via E. De Nicola, n. 42, Cosenza, Italy C.F/P.IVA: 03767240785 is among the obliged subjects defined in Legislative Decree 231/2007, in Article 3, paragraph 5, letters
(i) service providers related to the use of virtual currency;
(i-bis) digital wallet service providers.
As defined in Article 1, paragraph 2, letters:
(ff) service providers relating to the use of virtual currency: any natural or legal person who provides to third parties, in a professional capacity including online, services functional to the use, exchange, storage of virtual currency and their conversion from or into fiat currencies or into digital representations of value, including those convertible into other virtual currencies as well as issuing services; offer, transfer and clearing and any other service functional to the acquisition, trading or intermediation in the exchange of the same currencies;
(ff-bis) digital wallet service providers: any natural or legal person who provides, to third parties, on a professional basis, including online, private cryptographic key safeguard services on behalf of its customers, in order to hold, store and transfer virtual currencies;
Money laundering, pursuant to the Anti-Money Laundering Decree, means:
In relation to the risks associated with the phenomena of money laundering and terrorism, Reflex Token SRL responds responsibly, devoting the utmost attention to law enforcement and prevention tools.
In particular, it is up to the sole director to identify money laundering and terrorist financing risk management policies appropriate to the extent and type of risk profiles to which the activity of Reflex Token SRL is concretely exposed.
Roles and responsibilities in AML
For the purpose of mitigating the risk of involvement of Reflex Token SRL in matters of money laundering and / or terrorist financing, the involvement of the corporate bodies and the correct fulfillment of obligations is of primary importance.
The following paragraphs detail the tasks and responsibilities in the field of anti-money laundering of the corporate bodies of Reflex Token S.R.L.
Sole Director Reflex Token SRL
The sole director of Reflex Token SRL is responsible for defining the overall model of governance and management of the risk of money laundering and terrorist financing.
It is the task of the sole director pro-tempore to approve this Policy and the organizational model for the governance and management of this risk.
In particular, the sole administrator:
Anti-money laundering measures
Reflex Token SRL is committed to continuously spreading the culture aimed at the prevention and mitigation of money laundering and terrorist financing.
The action to prevent and combat money laundering and terrorist financing, implemented in Reflex Token SRL, is based on the following measures: