American Trade Exchange, Inc., doing business as Sequoir, complies with all applicable laws and regulations in each jurisdiction in which it operates.

Last updated: September 1, 2018

United States American Trade Exchange, Inc., the company which operates Sequoir in the U.S., is registered as a Money Services Business with FinCEN, 31000120483650. American Trade Exchange, Inc. is required to comply with a number of financial services and consumer protection laws, including:

  • The Bank Secrecy Act, which requires American Trade Exchange, Inc. to verify customer identities, maintain records of currency transactions for up to 5 years, and report certain transactions.
  • The USA Patriot Act, which requires American Trade Exchange, Inc. to designate a compliance officer to ensure compliance with all applicable laws, create procedures and controls to ensure compliance, conduct training, and periodically review the compliance program.

Anti-money laundering

Courts and jurisdictions are divided on whether or not digital and virtual currencies are a currency. Accordingly, digital and virtual currencies may or may not be "money" and, therefore, not subject to anti-money laundering statutes. American Trade Exchange, Inc. has developed a set of anti-money laundering policies that you must agree to abide by. These policies are designed to meet strict standards, including the existence of systems and controls to mitigate the risk presented to any person who accesses or uses the service. This includes, but is not limited to:

  • Establishing robust internal policies, procedures, and controls that strive to combat any attempted use of BOA for illegal or illicit purposes and to ensure our customer's basic protections under consumer protection laws;
  • Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network ("FinCEN");
  • Filing Suspicious Activity Reports ("SARs");
  • Filing Currency Transaction Reports ("CTRs");
  • Maintaining comprehensive records of orders and other transfers;
  • Appointing a Chief Compliance Officer who will be responsible for the implementation and oversight of our BSA/AML Program;
  • Executing Know Your Customer ("KYC") procedures on all customers;
  • Performing regular, independent audits of our BSA/AML program;
  • Following record retention requirements; and
  • Implementing a formal and ongoing compliance training program for all new and existing employees.

The American Trade Exchange, Inc. Customer Identity Program (“CIP) is an important part of our BSA/AML program. It helps us detect suspicious activity in a timely manner and prevent fraud. In accordance with this, in order to open an account, your identity must be verified, authenticated, and checked against government watch-lists, including the Office of Foreign Assets Control ("OFAC"). If you are an individual, prior to opening an account, American Trade Exchange, Inc. will collect, verify, and authenticate the following information:

  • Email address;
  • Mobile phone number;
  • Full legal name;
  • Social Security Number ("SSN") or any comparable identification issued by the government;
  • Date of birth ("DOB");
  • Home address (not a mailing address or P.O. Box); and
  • Additional information or documentation at the discretion of our compliance team.

American Trade Exchange, Inc. files required reports (i.e. Suspicious Activity Reports) if we know, suspect, or have reason to suspect suspicious activities have occurred. A suspicious transaction is often one that is inconsistent with a customer's known and legitimate business, personal activities, or personal means. Our compliance department monitors transactions to help identify unusual patterns of customer activity. In addition, all currency transactions over a determined amount are required to be reported to the US government (i.e. FinCEN). Our compliance department maintains records and supporting documentation of all reports filed.

All records are retained for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

Money Transmitter Licenses

American Trade Exchange, Inc. is in the process of obtaining money transmitter licenses in the following states. Money transmitter licenses are required per state in order to offer a peer-to-peer exchange service. Money transmitter licenses are not required by American Trade Exchange, Inc. when buying and selling directly with a verified user.



State Agency


Money Transmitter License (In Process)

Illinois Division of Financial Institutions


Money Transmitter License (In Process)

Wisconsin Department of Financial Institutions


Money Transmitter License (Planned)

Michigan Department of Insurance and Financial Services


Money Transmitter License (Planned)

Minnesota Department of Financial Institutions


Money Transmitter License (Planned)

California Department of Financial Institutions


Money Transmitter License (Planned)

Florida Financial Services Commission

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