Internal Controls
Compliance Officer
Training
Customer Verification Procedures
Monitoring of Transactions
AML (Anti Money Laundering) Program Audit
We have designed a bitcoin trading site structured system of internal controls in order to comply with applicable AML & KYC laws and regulations, some of which are outlined in this Policy including, but not limited to, our Customer Verification Procedures, filling Suspicious Activity Reports (“SARs”), as well as other requirements and audits.
The Compliance Officer is the person, duly authorized by the Company, whose responsibility is to develop and enforce the effective implementation of the AML & KYC Policy regarding btc buysell. The Compliance Officer is required to report any violations of the AML & KYC procedures and is responsible for collecting and filing SARs.
All employees receive a full AML & KYC training, along with a job‐specific guidance. Training is conducted at least once every twelve (12) months to ensure that trainees are informed and act in compliance with all applicable laws and regulations. New employees receive relevant training within thirty (30) days of their start date. Training program is updated regularly to reflect current laws and regulations.
The Company establishes its own customer verification procedures within the standards of AML & KYC frameworks. In order to open an account, customer’s identity and place of residence need to be verified and checked against sanctions and watch lists, including the Office of Foreign Assets Control (“OFAC”) and Politically Exposed Persons list (“PEP”).
In order to open an account for an individual customer, the following information needs to be verified:
Email address;
Mobile phone number;
Full name;
Proof of identity (government identity card, driver’s license, passport);
and
Additional information or documentation, if requested.
This cryptocurrency trading site uses customer transaction monitoring as a risk‐assessment and suspicious activity detection tool. If a transaction is inconsistent with a customer’s known personal activities or personal habits, this transaction may be considered suspicious. Data and transaction monitoring tools are used to identify uncommon patterns of customer’s activity. After review and investigation, it is Compliance Officer’s decision whether to file a SAR or not. Once a SAR is filed with a relevant agency, a copy of filing documentation is maintained onsite. SAR filing is confidential and only the Company’s employees involved in the investigation and reporting process will be aware of its existence.
All bitcoin exchange and other crypto exchange records are retained for eight (8) years and are available upon official request by an authorized examiner, regulator, or law enforcement agency.
The Compliance Officer is responsible for conducting AML & KYC audit at least annually. In addition, annual independent test of the AML & KYC procedures is done by a third party. In order to achieve segregation of duties, the Compliance Officer is not responsible for such independent test.
