1. Our Commitment
Vinmi Trade is committed to maintaining the highest standards of regulatory compliance and to actively combating money laundering, terrorism financing, and other forms of financial crime. We take our obligations under Australian law and AUSTRAC oversight seriously, and we have built our trading platform around compliance — not around it.
This policy summarises the principles and controls applied across Vinmi Trade’s operations. The full AML/CTF Program (Parts A and B) is maintained internally and reviewed by our AML/CTF Compliance Officer.
2. Regulatory Framework
Vinmi Trade is operated by VINMI Pty Ltd (ACN 678 785 469), an AUSTRAC-registered reporting entity holding both:
• Digital Currency Exchange Provider registration — DCE100875684-001
• Independent Remittance Dealer registration — IND100875684-001
Both registrations are current and remain valid until 15 November 2027.
Our operations are governed by:
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
• Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1)
• Privacy Act 1988 (Cth) and the Australian Privacy Principles
• Charter of the United Nations Act 1945 (Cth) and Autonomous Sanctions Act 2011 (Cth)
• Guidance and directions issued by AUSTRAC from time to time
3. Customer Due Diligence (KYC)
Before any client may use Vinmi Trade’s services, we conduct identity verification appropriate to the client type and assessed risk:
• Individual clients — full name, date of birth, residential address verified against government-issued photo identification and/or independent electronic data sources
• Corporate clients — ABN/ACN, registered office, beneficial ownership (≥ 25%), and identification of all directors and authorised signatories
• Trusts and other structures — trust deed, identification of trustees, settlors, appointors, and beneficiaries
We do not onboard anonymous accounts, accounts in fictitious names, or accounts where beneficial ownership cannot be reasonably established.
4. Enhanced Due Diligence
Enhanced due diligence is applied where the assessed money-laundering or terrorism-financing risk is higher, including but not limited to:
• Politically Exposed Persons (PEPs) and their close associates
• Clients located in, or transacting with, jurisdictions subject to FATF call-for-action or increased monitoring
• Transactions involving privacy-enhanced digital assets or unusual patterns
• Source-of-funds or source-of-wealth concerns
EDD outcomes are documented and signed off by the AML/CTF Compliance Officer.
5. Transaction Monitoring
All client transactions on Vinmi Trade are subject to ongoing monitoring against parameters defined in our AML/CTF Program, including transaction size, frequency, counterparty risk, wallet exposure, and behavioural deviation from the client’s expected profile. Alerts are investigated and, where warranted, escalated for reporting.
6. Sanctions and PEP Screening
All clients and counterparties are screened, at onboarding and on an ongoing basis, against:
• Australian Department of Foreign Affairs and Trade (DFAT) Consolidated List
• UN Security Council Sanctions List
• Other applicable international sanctions lists
• Politically Exposed Persons databases
Vinmi Trade does not provide services to sanctioned individuals, entities, or jurisdictions.
7. Reporting Obligations
Where required by the AML/CTF Act, Vinmi Trade lodges the following reports with AUSTRAC:
• Threshold Transaction Reports (TTRs) — for cash transactions of AUD 10,000 or more (or foreign currency equivalent)
• International Funds Transfer Instructions (IFTIs) — for cross-border transfers
• Suspicious Matter Reports (SMRs) — where reasonable grounds exist to suspect a matter relates to a money-laundering, terrorism-financing, or other prescribed offence
• Compliance Reports — annual AUSTRAC compliance report
Clients are not notified when an SMR has been filed, in accordance with the tipping-off prohibition under section 123 of the AML/CTF Act.
8. Record Keeping
Vinmi Trade retains all customer identification records, transaction records, and AML/CTF-related documentation for a minimum of seven (7) years from the end of the customer relationship or the date of the transaction, whichever is later.
9. Staff Training
All personnel, contractors, and directors involved in Vinmi Trade’s operations receive AML/CTF awareness training at induction and on a recurring basis. Training is tailored to role, risk exposure, and changes in the regulatory environment.
10. AML/CTF Compliance Officer
Vinmi Trade has appointed an AML/CTF Compliance Officer with primary responsibility for the design, oversight, and ongoing operation of our AML/CTF Program, including liaison with AUSTRAC and other regulators.
The Compliance Officer can be contacted at compliance@vinmitrade.com.au.
11. Independent Review
The Vinmi Trade AML/CTF Program is subject to independent review at intervals consistent with the AML/CTF Rules. Findings are reported to senior management and inform program updates.
12. Updates to this Policy
This policy is reviewed at least annually and updated whenever there are material changes to applicable law, AUSTRAC guidance, or Vinmi Trade’s operations. The latest version is always available on our website.
13. Contact
VINMI Pty Ltd (trading as Vinmi Trade)
‘B4’, 41 Roberts Road, Chullora NSW 2190
Phone: (02) 8355 2866
General enquiries: info@vinmitrade.com.au
Compliance: compliance@vinmitrade.com.au