AX420 Inc. (“AX420”) is the sole owner of the AX420 exchange and the primary partner of the AX420 LP. Insofar as required, AX420 complies with the all guidelines, rules and regulations set out by all regulatory and compliance institutions with the intent of providing the most secure user experience for our clients.
AX420 operates in concert with the Customer Protection Rule Section 15(c)(3) of the Securities Exchange Act of 1934 and Rule 15c3-3 thereunder. AX420 model reflects the ideals of the regulators.
Where AX420 LP receives client funds, those funds are compliantly safeguarded for our users at one or more of our banking or securities partners with full transparency to our users. AX420 ensures that at all times, the user maintains control and visibility over his assets. We do this by “posting” user asset and cash “positions” for independent validation. The user is then able to benefit from the relationships, partnerships and gateways constructed by AX420 Inc.
Third-Party Partners may on occasion collect deposits, make payments and process transactions for our customers, users and partners. Naturally, AX420 and its partners are compliant within the jurisdictions in which they operate and use compliant models to invoke, assure and maintain client protection to the highest standard.
AX420 has implemented procedures to cover key areas within our compliance framework.
Know Your Customer (KYC) Onboarding Process Procedures
AX420 is committed to Know Your Customer (KYC). As prescribed by law, we adhere to strict procedures to verify our customers. AX420 has a compliant on-boarding process that reflects industry standards. During a customer’s onboarding process, AX420 collects and verifies documentation to substantiate the customer’s identity. AX420 uses this information to implement AX420’s Anti-Money Laundering (AML) policy. Although AX420 is not deemed a financial institution, it has opted to participate in a Customer Identification Program (CIP). For regulated financial institutions, CIP is a provision of the USA Patriot Act and is incorporated as part of the Bank Secrecy Act/AML Compliance Program.
Summary of the Anti-Money Laundering Compliance Program
AX420 maintains a strict policy against money laundering and is fully committed to following applicable laws, rules and regulations as if it were a regulated entity. To ensure that AX420 facilities are not used for money laundering purposes, the company maintains an anti- laundering compliance program, which (i) requires employees to gather certain information regarding the true identity of customers, and (ii) requires employees to report suspicious users and transactions to the designated AX420 supervisory personnel, principals and/or the compliance officers, who may submit SARs to the relevant authorities.
AX420 also requires that appropriate personnel complete periodic training sessions, which focus on AX420 policies and procedures in concert with prevailing laws regarding anti-money laundering and know your client. AX420 maintain records of its programs.
AX420 does not handle cannabis products directly. As such, AX420 is not required to be a licensed cannabis company in any jurisdiction in which it operates. AX420 understands that our users are licensed participants in their respective states, countries or jurisdictions.
AX420 acknowledges that regardless of the local laws, cannabis is still considered a controlled substance under the Controlled Substance Act (CSA) within the jurisdiction of the United States.
The AX420 marketplace and the services which we provide are intended to help meet the obligations of our users, partners and customers under the laws within their state, country or jurisdiction. Each customer and/or member’s jurisdiction has regulations that are specific to both recreational and medicinal marijuana. AX420 is aware of these laws, rules and regulations but recommends that the user always seek independent counsel when unsure of their legal position.
Last Updated: 4 20 2020