Anti-money Laundering and Know Your Customer Policy
The purpose of Anti-Money Laundering and Know Your Customer Policy (AML/KYC Policy) is to identify, prevent and mitigate possible risks of being involved in illegal activity.
These rules of procedure for prevention of money laundering, terrorist financing and compliance with international sanctions lay down requirements for screening the Clients and Transactions in order to prevent entering into deals involving suspected money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery to ensure identification and reporting of such.
This policy includes verification procedures, compliance officer, monitoring transactions and risk assessment.
1. Verification procedures
BtcPremium would determine and take due diligence (hereinafter DD) measures using results of conducted risk assessment, and provisions of national risk assessment.
BtcPremium pays special attention to the activities of clients participating in a transaction and to circumstances that refer to Money Laundering or Terrorist Financing, including to complex, high-value or unusual transactions which do not have any reasonable economic purpose.
Depending on the level of the risk of the client and/or transaction and depending on the fact whether the business relationship is an existing one or it is about to be established, BtcPremium applies either normal DD measures , simplified DD measures or enhanced DD measures. BtcPremium also applies continuous DD measures to ensure ongoing monitoring of business relationships.
The identification procedure requires the user to provide BtcPremium with reliable, independent source documents, data or information (f.e., national ID card, international passport, extract from the bank, utility bill, selfie picture). The document presented for identification of a legal person shall set out at least the following: business name, registry code (number), date of registration, seat and address; names and authorisations of members of the Management Board or the head of branch or the other relevant body. A legal representative of a new client (subsequently as required) shall confirm the correctness of the submitted information.
For such purposes, BtcPremium reserves the right to collect the User’s identification information for the purposes of AML / KYC Policy compliance.
Once the user’s identity has been verified, BtcPremium is able to remove itself from potential legal liability in a situation where its services are used to conduct illegal activity.
2. Compliance officer
The compliance officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity. The CO’s principal tasks are to:
Monitor the compliance of the Rules with the relevant laws and compliance of the activity of the Representatives with the procedures established by the Rules;
Compile and keep updated the data regarding countries with low tax risk, high and low risk of Money Laundering and Terrorist Financing and economical activities with great exposure to Money Laundering and Terrorist Financing;
Report to the MB once a year (or more frequently, if necessary) on compliance with the Rules, and on Transactions with a suspicion of Money Laundering or Terrorist Financing;
Collect, process and analyse the data received from the Representatives or Clients concerning suspicious and unusual activities;
Make proposals on remedying any deficiencies identified in the course of checks.
3. Monitoring transactions
BtcPremium reserves the right to monitor transactions against fraud purposes, which relies on data analysis as a risk-assessment and suspicion detection tool. Suspicious transactions will be investigated and reported through the CO.
These activities could be for example: withdrawal without trading, duplicate user, withdrawal from different country. (Not a complete list.)
BtcPremium reserves the right to terminate user’s account when BtcPremium is detecting reasonably suspicion in illegal activity.
4. Risk assessment
BtcPremium will establish a risk profile of a Client based on information gathered under the Rules.
BtcPremium applies the following risk categories:
4.1 Normal risk (the risk level is normal, there are no high risk characteristics present);
4.2 High risk, which is subcategorized as High risk I and High risk II.
For every Client, who does not fall into the “normal risk” categoryBtcPremium will record the client’s risk category in the database of clients and on the documents as “High risk I” or “High risk II”. Only the CO shall have the right to change the risk category recorded for a client.