BITEXBIT AML/KYC POLICY
Last amended: December 12, 2020
Please read carefully this Anti-Money Laundering / Know Your Customer Policy (hereinafter the “AML/KYC Policy”, “Policy”) before using a website at https://bitexbit.com or any our Services.
This Policy is designated to prevent and mitigate possible risks of Bitexbit being involved in any kind of illegal activity, such as money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery. Policy complies with applicable legal regulations and will be reviewed, updated on a regular basis to ensure appropriate policies, procedures and internal controls.
AML/KYC Policy covers the following matters:
Identification and Verification procedures;
Sanction policy and PEP lists screening;
Bitexbit has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML/KYC legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the User identification / verification, the suspicious activity monitoring and reporting.
Bitexbit reserves the right to collect User’s identification information for the AML/KYC Policy purposes. Users may be identified using a variety of methods. Bitexbit may (1) cross-check the names of Users against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists; (2) require Users to provide proof of identification; (3) refuse from transactions with any person identified as a “Specially Designated National” and other persons set forth herein; and/or (4) determine whether it is necessary to inform the appropriate authority according to applicable laws and regulations.
IDENTIFICATION AND VERIFICATION PROCEDURES
Identification. Our identity verification procedure requires the User to provide with reliable, independent source documents, data or information (for example, national ID, international passport, bank statement, utility bill). Such documents shall be sent in high-quality color format. Bitexbit reserves the right to reject any documents, which do not comply with the above.
Bitexbit requires such documents, data or information to enable the User identification; verify the identity of each User; record User’s identification information and the verification results; and compare User identification information with government-provided lists of suspected terrorists, once the government has issued such lists. For such purposes Bitexbit reserves the right to collect User’s identification information.
Verification. Bitexbit will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Bitexbit reserves the right to investigate certain Users who have been determined to be risky or suspicious. In addition, Bitexbit reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). Bitexbit also reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
SANCTION POLICY AND PEP LISTS SCREENING
Bitexbit may refuse from transactions with any person identified as a “Specially Designated National”, United States citizen or permanent resident of the United States, nor has a primary residence or domicile in the United States, including Puerto Rico, the U.S. Virgin Islands, and any other possessions of the United States. Bitexbit may also refuse from transacting with citizens and residents of unrecognized territories and/or states.
Bitexbit may refuse from transactions with individuals, companies and countries that are on prescribed Sanctions lists. Bitexbit will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate. Bitexbit also screens Users against recognized Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists: (i) on the onboarding stage when the user is submitting the application; and (ii) on each anti-fraud and AML alerts manually by Compliance Officer.
The Compliance Officer is the person, duly authorized by Bitexbit, and fully responsible for implementing and enforcing AML/KYC program. The duties of the Compliance Officer with respect to this Policy shall include, but are not limited to:
Collecting Users’ identification information;
Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
Maintaining necessary and appropriate records;
Monitoring transactions and determining any suspicious activity;
Ensuring independent audits of the AML/KYC policy;
Providing law enforcement with information as required under the applicable laws and regulations;
The Compliance Officer is entitled to interact with law enforcement authority, which is involved in prevention of money laundering, terrorist financing and other illegal activity.
SUSPICIOUS ACTIVITY MONITORING AND REPORTING
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Bitexbit may monitor transactions to detect the suspicious activity.
For the purposes of this Policy suspicious activity may be defined as the transaction which (1) involves funds derived from illegal activity or is intended or conducted to hide or disguise funds or assets derived from illegal activity; (2) is designed, whether through structuring or otherwise, to avoid any recordkeeping or reporting requirements of the regulations; (3) has no business or apparent lawful purpose; or (4) facilitates criminal activity, including the use of Bitexbit in such actions.
Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Bitexbit reserves the right to request the User to provide any additional information and documents in case of suspicious transactions; and suspend or terminate User’s Account when Bitexbit has reasonably suspicion that such User engaged in illegal activity.
The Compliance Officer shall file a report, including supporting documentation, to notify the appropriate authority in situations involving violations requiring immediate attention, such as terrorist financing, continued money laundering schemes or other financial crime. And Bitexbit reserves the right to file a voluntary report for any suspicious transaction that we determined as a potential violation of any law or regulation.
Pursuant to the international requirements the Bitexbit has adopted a risk-based approach towards assessing and managing the money laundering and terrorist financing risks. Therefore, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. The principle is that resources should be directed accordingly to priorities so that the greatest risks receive the highest attention.