Financial crime & compliance

Zodia Custody adheres to a comprehensive AML/CTF and Sanctions compliance framework which is underpinned by effective risk identification, assessment and mitigation in order to protect our clients, and prevent the digital asset ecosystem from being used to enable financial crimes.

Zodia Custody has in place policies, standards, systems and controls to achieve this, including, but not limited to:

• Effective risk and compliance governance and oversight via committees.
• Policies and standards for AML/CTF, Sanctions, Travel Rule, Client Due Diligence. Transaction monitoring and Name Screening.
• Tooling which provides Transaction monitoring, Transaction screening, name screening and fraud monitoring capabilities.
• Ongoing monitoring and testing.
• Employee training.

At Zodia Custody, we are committed to maintaining the highest standards of integrity and transparency in all our business dealings. We have a zero-tolerance policy towards bribery and corruption and strictly prohibit any form of bribery, whether direct or indirect, involving our employees, clients, or third-party associates.

We are committed to conducting our business with utmost fairness and transparency, including effective management and mitigation of potential conflicts of interest.

Our ABC Policy and Conflicts of Interest Policy mandate:

• Disclosure of any personal or financial interests that could conflict with Zodia Custody’s operations, or that of its clients.
• Avoidance of actions or relationships that could compromise impartiality or professional judgment.
• Prohibition of offering, giving, soliciting, or accepting any form of bribe.
• Thorough due diligence on all potential business partners, clients, and transactions to ensure compliance with anti-bribery laws.
• Regular employee training on anti-bribery policies and procedures.
• Ongoing monitoring and periodic reviews of our anti-bribery controls to ensure compliance with legal and regulatory standards.

At Zodia Custody the privacy and protection of your personal data are of utmost importance. We are committed to maintaining the highest standards of data security and privacy to ensure your information is safe and secure.

Zodia Custody has a Privacy Policy which underpins Zodia Custody’s practices with respect to data protection and privacy. This ensures compliance with all applicable data protection laws and regulations and includes controls with respect to conducting privacy impact assessments (PIA), maintaining a record of processing activities (ROPA), conducting third party privacy assessments and overall embedding privacy by design, into Zodia Custody’s ways of working.

For further information please refer to Zodia Custody’s Privacy Policy & Cookies.

Zodia Custody is committed to maintaining the highest standards of ethical conduct and integrity. To ensure a transparent and accountable environment for both our clients and employees, we have established robust conduct and whistleblowing controls that allow issues to be raised without fear of retaliation.

Our ‘Speaking Up’ Programme encourages and empowers individuals to report breaches of policies, regulatory requirements, or unacceptable behavior. This programme fosters a culture where people feel safe to speak up, trust that risk and compliance matters will be addressed, and are confident that any identified misconduct will be appropriately dealt with. The programme is shared with individuals upon joining, easily accessible, and continuously reinforced through training.