AML Policy

Updated On - 31 March 2022

AML Policy

 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:


  1. the conversion or transfer of property, carried out knowing that it comes from a criminal activity or from a participation in such activity, with the aim of concealing or concealing the illicit origin of the property or of helping any person involved in such activity to escape the legal consequences of his actions;
  2. the concealment or concealment of the true nature, provenance, location, disposition, movement, ownership of the property or rights therein, carried out on the knowledge that such property originates from criminal activity or from participation in such activity;
  3. the acquisition, possession or use of property being aware, at the time of their receipt, that such property originates from criminal activity or participation in such activity;
  4. participation in one of the acts referred to in points (a), (b) and (c), the association to commit that act, the attempt to commit it, the fact of helping, instigating or advising someone to commit it or facilitating its execution.


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:


  •  periodically develop guidelines and  policies  for  the management of risks related to money laundering;  
  • approves a policy that illustrates the choices that Reflex Token SRL makes regarding  internal  procedures and controls, verification and storage of data,  based on the actual exposure to the risk of money laundering (so-called anti-money laundering policy);
  • approves the principles for the management of relations with customers classified as "high risk";
  • ensure the protection of confidentiality in the context of the procedure for reporting suspicious transactions;
  • assess the risks resulting from operations with third countries associated with   higher money laundering risks, identifying risk-related strategies and tools.

 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:


  • Customer due diligence; Registration of reports and operations and storage of related supporting documents;
  • Adoption of organizational procedures and internal control controls;
  • Monitoring and reporting of suspicious transactions;
  • Staff training.