Anti–Money Laundering Policy, countering the financing of terrorism and the “Know Your Customer” Policy (hereinafter referred to as the “AML/CFT Policy”) btc-obmennik.com designed to prevent and reduce possible risks of involvement btc-obmennik.com in any kind of illegal activity.
Money laundering is defined as
transformation or transfer of property obtained as a result of criminal activity, or property received in return for such property, if it is known that such property was obtained as a result of criminal activity or as a result of participation in such activity, for the purpose of concealing or concealing the illegal origin of property or assisting any person involved in the commission of such activity in evasion from the legal consequences of this person’s actions;
acquisition, possession or use of property obtained as a result of criminal activity, or property received in return for such property, knowing at the time of receipt that such property was obtained as a result of criminal activity or as a result of participation in it;
concealment or concealment of the true nature, source, location, disposition, movement, rights in relation to or possession of property obtained as a result of criminal activity, or property obtained instead of such property, if it is known that such property was obtained as a result of criminal activity or as a result of an act of participation in such activity.
Money laundering also means participation, complicity in the commission, attempts to commit and aiding, abetting, assisting and advising in the commission of any of the actions mentioned above.
The financing of terrorism is defined as the financing and support of a terrorist act and its commission, as well as the financing and support of travel for the purpose of terrorism.
Both international and local laws and regulations require that btc-obmennik.com implementation of effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, as well as taking measures in case of any form of suspicious activity on the part of its Users.
The AML/CFT policy covers the following issues
internal controls
Compliance Officer;
staff training;
verification procedures;
monitoring, risk assessment and risk-based approach;
Audit of the AML/CFT program.
Internal control
We have developed a structured internal control systеm in order to comply with applicable laws and regulations on combating money laundering and terrorist financing (hereinafter referred to as “AML/CFT”), including, but not limited to:
identification of the client and verification of the information provided;
establishing a special regime for working with clients who are politically exposed persons (PPL);
identifying unusual activities and facilitating the reporting of suspicious activity (SAR);
accounting of client documentation and transaction history.
Compliance Officer
A compliance officer is a person duly authorized btc-obmennik.com , whose responsibilities inсlude developing and ensuring the effective implementation of AML/CFT. The Compliance Officer is required to report any violations of the AML/CFT procedures and is responsible for collecting and submitting the OPO.
The Compliance Officer is responsible for overseeing all aspects of the measures btc-obmennik.com anti-money laundering and terrorist financing, including, but not limited to:
establishing and updating internal policies and procedures for completing, verifying, submitting and storing all reports and records required in accordance with applicable laws and regulations;
collection of user identification information and verification of the information provided; implementation of a records management systеm for proper storage and retrieval of documents, files, forms and logs;
collection and analysis of information concerning unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing that have become apparent; investigation of any unusual, suspicious activity;
report to the relevant authorities in case of suspicion of money laundering or terrorist financing; provide information to law enforcement agencies in accordance with the requirements of applicable laws and regulations;
periodic submission to the Management Board of written statements on compliance with the requirements arising from the law;
organization of employee training;
performance of other duties and responsibilities related to compliance with legal requirements; regular updating of the risk assessment.
Compliance Officer has the right to interact with law enforcement agencies that are engaged in the prevention of money laundering, terrorist financing and other illegal activities.
Training
All employees are fully trained in AML/CFT, as well as receive job recommendations. Trainings are conducted at least once every twelve (12) months to ensure that trainees are informed and act in accordance with all applicable laws and regulations. If necessary, employees undergo additional training (in case of adoption of a new law or regulatory act, if required by law, etc.) New employees undergo appropriate training before starting work. The training program is regularly updated taking into account current laws and regulations.
Verification procedures
btc-obmennik.com establishes its own customer verification procedures within the framework of AML/CFT standards.
btc-obmennik.com conducts due diligence and KYC checks before entering into business relations with the customer, the customer, the contractor.
In the process of due diligence and KYC, as well as to open an account, the person’s identity, the information provided about the person and the documents submitted must be checked and checked against the sanctions lists and surveillance lists, including the list of politically significant persons. For this btc-obmennik.com uses special tools, a structured systеm of verification and verification.
In relation to legal entities (their owners/shareholders/beneficiaries, etc.) btc-obmennik.com conducts special enhanced due diligence, KYC, compliance procedures.
btc-obmennik.com provides special extended identification, KYC, due diligence, compliance procedure for clients referred to as politically exposed persons, regardless of their place of residence.
Monitoring, risk assessment and risk-based approach
btc-obmennik.com monitors customer transactions, assesses risks and identifies suspicious activities. For this purpose, a specially developed systеm is used, including using high-performance tools.
btc-obmennik.com uses a risk-based approach to combating/preventing money laundering and/or terrorist financing.
To help determine the level of due diligence in the field of AML/CFT in relation to the client, the compliance risk profile is calculated first when entering into a relationship (Low, Medium, High), and then recalculated as planned.
AML/CFT compliance ensures ongoing transaction monitoring to identify transactions that are unusual or suspicious compared to the customer profile.
Determining the unusual nature of one or more transactions significantly depends on the subjective assessment of the client’s awareness (KYC), his financial behavior and the counterparty to the transaction.
If the transaction is incompatible with the known personal routine activities or personal habits of the client, this transaction may be considered suspicious. Data and transaction monitoring tools are used to identify unusual/unusual patterns of customer behavior. After review and investigation, the Regulatory Compliance Officer decides whether to file a SAR or not.
After the SAR is submitted to the relevant agency, a copy of the registration documentation is saved.
SAR filing is confidential, and employees only btc-obmennik.com those involved in the investigation and reporting process will be aware of its existence.
All records are kept for at least (5) years and are available at the official request of an authorized inspection, regulatory or law enforcement agency.
Any employee btc-obmennik.com must inform the Compliance Officer of any atypical transactions that they observe and which cannot be attributed to a legitimate activity or source of income known to the client.
AML/CFT Audit
The Compliance Officer is responsible for conducting an AML/CFT audit at least once a year. Other audit requirements are set out in internal policies and procedures.
We apply due diligence measures, in particular
when establishing business relationships;
when verifying information obtained through the application of due diligence measures, or in case of doubts about the sufficiency or reliability of previously collected documents or data when updating the relevant data;
suspected of money laundering or terrorist financing;
in some other cases, including in other specific cases provided for by law, and in cases of identification of “red flags” in accordance with internal procedures.
Saving data
We retain originals or copies of documents that serve as the basis for identification and verification of persons, as well as documents that serve as the basis for establishing business relations at least five years after the termination of business relations.
We store documents prepared in relation to the transaction on any data carrier, as well as documents and data that serve as the basis for notification obligations, for at least five years after the transaction is completed or the obligation to provide a report is fulfilled.
Our monitoring of business relationships includes, in particular
, checking transactions made within the framework of business relationships to ensure that transactions correspond to our knowledge of the client, his activities and risk profile;
regular updating of relevant documents, data or information collected during the application of due diligence measures;
determining the source and origin of the funds used in the transaction;
pay more attention to operations that may be related to money laundering or terrorist financing, including complex, expensive and unusual operations and schemes of operations that do not have a reasonable or visible economic or legitimate purpose or that are not typical for considering the specifics of the business;
pay more attention to business relationships or transactions in which the client (or the payment service provider, etc. of the client) is located from a third country with a high level of risk or a country or territory defined by law as a country or jurisdiction with a factor(s) that increase the risk of geographical risk.
