Spencer Logic provides white-label brokerage and exchange infrastructure, including risk-intelligence and monitoring technology, to regulated and regulation-seeking financial services businesses. This policy describes our own commitment to anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) standards as a technology and infrastructure provider, and clarifies how our platform supports — without replacing — each client’s independent regulatory obligations.
As a vendor, Spencer Logic maintains a risk-based due diligence process for prospective and existing clients, including counterparty screening against applicable sanctions lists (e.g., OFAC, UN, EU consolidated lists) and politically exposed persons (“PEP”) checks, and reserves the right to decline or discontinue service to any counterparty presenting unacceptable financial-crime risk.
Clients that use Spencer Logic’s infrastructure — including brokers and exchanges operating under the ProtonX platform — remain independently responsible for holding the licenses, registrations, and AML/CFT program required in their operating jurisdictions, including their own Money Laundering Reporting Officer function, suspicious activity reporting, and regulator engagement. Spencer Logic’s tools support this program; they do not substitute for it.
Spencer Logic maintains internal policies covering employee due diligence, confidentiality of client and end-user data, and periodic training on financial-crime risk indicators relevant to our role as an infrastructure provider.
Employees, clients, and partners who become aware of activity that may violate this policy are encouraged to raise the matter promptly with their Spencer Logic account contact or compliance point of contact.
Spencer Logic cooperates with lawful requests from regulators and law enforcement to the extent required by applicable law and the terms of our client agreements.
This policy is reviewed periodically and updated to reflect changes in our business, applicable law, and industry practice.
Questions about this policy can be directed to our team via the Contact options on our Site.
This page is a general template provided for convenience and does not constitute legal advice. It should be reviewed and adapted by qualified legal and compliance counsel to reflect Spencer Logic’s specific corporate structure, licensing status, and the jurisdictions in which it and its clients operate before being relied upon.