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NAX Capital Risk Policy

Purpose of This Risk Policy

This Risk Policy forms part of NAX Capital's risk management and compliance framework and is prepared for the purposes of meeting obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), associated AUSTRAC Rules, and other applicable Australian laws.

The purpose of this Risk Policy is to document how NAX Capital identifies, assesses, manages and mitigates risks associated with its designated services, including money laundering and terrorism financing (ML/TF), operational, customer, geographic, product, technology and regulatory risks.

This Policy is risk-based and proportionate to the nature, size and complexity of NAX Capital's business.

Risk Policy Approval and Governance

This Risk Policy is approved by the Board of Directors (or senior management, as applicable) of NAX Capital. Responsibility for implementation, oversight and ongoing review rests with senior management and the appointed AML/CTF Compliance Officer.

This Policy is reviewed at least annually, and more frequently where there are material changes to NAX Capital's business model, products, customer base, delivery channels or regulatory obligations.

Risk Policy Consent

By accessing or using NAX Capital's services, customers acknowledge that NAX Capital applies risk-based controls and restrictions in accordance with this Risk Policy, including customer due diligence, transaction monitoring, limits and account restrictions.

Customers who do not accept these measures must not use NAX Capital's services.

Changes to This Risk Policy

NAX Capital may amend this Risk Policy from time to time to ensure continued compliance with applicable laws, AUSTRAC guidance and regulatory expectations. Material changes will be communicated where required.

Who This Risk Policy Applies To

This Risk Policy applies to:

  • All designated services provided by NAX Capital;
  • All customers, including individuals and legal entities;
  • All directors, officers, employees and contractors of NAX Capital; and
  • All outsourced and third-party service providers involved in designated services.

Risk Management Framework

NAX Capital applies a structured risk-based framework that:

  • Identifies inherent risks relevant to its designated services;
  • Assesses the likelihood and potential impact of those risks;
  • Applies controls proportionate to the assessed risk;
  • Monitors customer behaviour, transactions and emerging risks on an ongoing basis; and
  • Updates systems, controls and procedures in response to changes in the risk environment.

Overall Risk Assessment

Having regard to its products, customer types, delivery channels and geographic exposure, NAX Capital currently assesses its overall ML/TF risk as medium.

This assessment is documented in NAX Capital's ML/TF Risk Assessment and is reviewed periodically.

Risk Categories and Mitigation Measures

Product and Delivery Channel Risk

NAX Capital provides over-the-counter and related digital asset services against fiat currency (AUD), primarily via online channels.

Inherent risks associated with digital assets include pseudo-anonymity, rapid transferability and volatility. Mitigating measures include:

  • Limiting services and assets offered based on operational readiness;
  • Applying transaction limits linked to customer verification and risk rating;
  • Pre-launch risk assessments for new products and delivery channels; and
  • Ongoing monitoring of product-related risks.

Customer Risk

NAX Capital services both individual and non-individual customers, including companies, trusts and partnerships.

Customer risk mitigation measures include:

  • Customer identification and verification in accordance with the AML/CTF Act and AUSTRAC Rules;
  • Screening against sanctions, PEP and adverse media lists;
  • Application of enhanced customer due diligence for higher-risk customers;
  • Ongoing customer due diligence and transaction monitoring; and
  • The ability to refuse, restrict or terminate customer relationships where risks cannot be adequately mitigated.

Geographic Risk

NAX Capital primarily services Australian residents. Overseas customers may be accepted subject to risk assessment.

Customers connected to high-risk jurisdictions are not accepted. High-risk jurisdictions include those:

  • Identified by FATF as high-risk or non-cooperative;
  • Subject to Australian, DFAT or UN sanctions;
  • Prescribed under the AML/CTF Act; or
  • Otherwise assessed by NAX Capital as presenting unacceptable risk.

Restricted jurisdiction lists are maintained and reviewed regularly.

Operational and Transaction Risk

NAX Capital does not accept or disburse physical cash. Fiat transactions are conducted through reputable Australian ADIs in the customer's own name.

Operational risk controls include:

  • Transaction monitoring and record-keeping;
  • Blockchain analytics and source-of-funds screening;
  • Due diligence on digital asset liquidity and supply providers;
  • Segregation of duties, approval thresholds and manual oversight; and
  • Periodic review of staffing and operational capacity.

Technology and Security Risk

NAX Capital maintains technical and organisational safeguards to protect systems, data and customer assets, including access controls, monitoring and incident response procedures.

Residual technology risk remains and is managed through continuous monitoring and improvement.

Compliance and Regulatory Risk

NAX Capital is committed to complying with all applicable Australian laws, including:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
  • AUSTRAC Rules and guidance;
  • Corporations and consumer protection legislation; and
  • Privacy and data protection laws.

Compliance obligations are supported through policies, procedures, training and independent review.

Risk Monitoring and Review

NAX Capital conducts ongoing monitoring of risks and reviews this Risk Policy at least annually or upon material change.

Findings from monitoring, audits, incidents and regulatory feedback are incorporated into updates to this Policy and related controls.

Contact Us

For enquiries regarding this Risk Policy or NAX Capital's risk management framework, please contact us at: [email protected].