AML Policy

Bitnexo Anti-Money Laundering Policy

PUBLIC VIEW

Last Amendment: May 24th 2016

10.1. Scope Of These AML Policies

These Anti-Money Laundering Policies exclusively apply to all remittance services performed and offered in the Websites and or other mediums of contact by Bitnexo, present or future and to the aperture, use and closure of a client's Bitnexo Account and other related services as to referred herein. Drafted to prevent money laundering and associated crimes, this policy, together with General Terms of Use, Internal Policies, procedures and other policies that may apply to specific legal relationships that Bitnexo may take part in, conform the legal relationship between Bitnexo and Third Parties of any nature. For additional services clients may have to accept additional terms and conditions of use. In addition to the type of Bitnexo account the user might have, additional terms and conditions of use may apply.

10.2. Definitions & Introductory Terms

The following terminology will be applied to these AML Policies and any or all possible annexing documentation: “AML” acronym; Anti-Money Laundering when referring to compliance and actions taken to prevent Money Laundering crimes. “FATF” Financial Action Task Force (FATF) referring to the inter-governmental body for combating money laundering, terrorist financing. “KYX” to generalize the term Know Your Customer and/or Know Your Agent. “CIP” in combination with Bitnexo will form: Customer Identification Program. “CDD”. “RBA” as in Risk Based Approach for and with all Legal Relationships. “SAR” or Suspicious Activity Report and/or Suspicious Activity Reports for generated reports or flagged activities. “CTF” Counter Terrorism Financing where applicable. “Initiator”, “client”, “verified customer”, “customer”, when referring to the individual, person or corporation accessing the site and services. Also considering “BITNEXO”, “BENEFICIARY”, “WE”, “REMITTANCE SERVICE”, “SERVICE”, “SERVICES” is referring to BITNEXO as a provider of the described service. “PARTY”, “PARTIES” or “US” refer to both the CUSTOMER & BITNEXO or BITNEXO & the CUSTOMER. “FIAT” refers to legal tender money such as USD, CLP, CYN (ISO 4217). “CRYPTO”, “BITCOIN”, “BTC” refers to Crypto-Currency in any of its existence when not specified.

10.3. Compliance To Regulatory Frameworks In Other Jurisdictions

Bitnexo is committed to the highest standards of AML & other punishable criminal acts derived from Money Laundering. In order to archive full regulatory compliance Bitnexo may reserve the right to refuse any kind of service, registration to initiate or receive any type of FIAT or BTC transmission, or to bar transmissions from or to anyone from or in any jurisdictions that do not meet international AML–CTF standards as set out by the FATF. Bitnexo must and will adhere to all applicable laws and regulations in all countries where it conducts indirectly or directly any type of business and/or business relationships with.

Bitnexo's AML policies strive to achieve AML, CTF & KYX strategies, goals and targets on an ongoing basis to maintain an adequate compliant program for Bitnexo's business relationships that echoes the best practices for a diversified, global financial services provider. Bitnexo identifies money laundering as the universal criminal practice of concealment of the economical proceeds of crime. Which are maliciously disguised so that it gives the appearance of legitimate income. Users and/or Bitnexo directly hired staff and all employees are required to adhere to these Policies in order to assure Bitnexo's past, preset and future reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.

10.5. General Overview Bitnexo-CIP

At all times users direct or indirect can be subject to augmented CDD scrutiny and procedures in your use of any Bitnexo service. Bitnexo can be classified as unregulated financial activity and yet to be regulated activities withing the money transmission realm and the Blockchain transport layer. Bitnexo might and might not fall within the scope of internationally enforced AML and/or CTF obligations dependent of applicable Jurisdiction. BUT this does not exempt Bitnexo to observe and comply to specific regulations per jurisdiction. Bitnexo has and is constantly devoting resources to have and implemented systems and procedures to meet general AML legislation, serving FATF's recommendations and specifications on he objectives of the FATF which are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system.

The creation of a dedicated CIP as main component of every Bitnexo's business relationships reflects the due diligence with and in all jurisdictions to prevent money laundering and not be used by criminals to launder proceeds of crime. Not limited to in any case by:

  • Constituting and sustaining a risk-based CIP which will include but not limited to verification scrutiny and KYX procedures, including augmented due diligence for those customers presenting higher risk & others.
  • Bitnexo's CIP is arranged to prevent money laundering by reaching and implementing FATF Recommendations which dictate international anti-money laundering and combating the financing of terrorism and proliferation (AML/CFT) standards, and the FATF Methodology to assess the effectiveness of AML/CFT systems.
  • Training and awareness for all relevant employees that take part in the transmission of FIAT and/or BTC.
  • The assignment of a dedicated Compliance Officer who has adequate level of independence and confidentiality responsible to inspect compliance with relevant legislation and regulation. Compliance enforcement not limited to Officer with resources to perform CDD effectively such as but not limited to:
    • Design, operate and maintain the compliance legal structure.
    • Certify all employees in personal identification and trained to preform CDD and spot potential risks and liability.
    • Defensive monitoring respected and applied over General Terms of Use, Policies internal/external, procedures, CDD and others. By employees and third parties.
    • Any action constituting a obligation including the need to have programmatically preforming systems and controls in place to mitigate the risk of Bitnexo being used against its Polices.
  • Constituting and sustaining RBAs towards assessing and managing Money Laundering and/or any Illicit Activity.
  • Constituting and sustaining RBAs and procedures to defensive monitoring of customer activity & its transmissions.
  • Internal programmatic procedures for reporting & generating SARs and its proper communication to relevant authorities if Sanctions Policy is violated.
  • Proper maintenance of complete records for the minimum prescribed periods described in relevant policies such as Backup and Restore Policy, Server Security Policy, Loss of Data Policy, Confidential Data Policy and/or others.

10.6. KYX Due Diligence

Bitnexo's forceful AML, KYX and CIP is associated but not limited to other Terms and Policies that might apply to any or all business relationship.

Internal Bitnexo KYC procedure includes Customer Identification procedures and flags for:

  • Individual KYC Guidelines for Individual Customer Identification Program
  • Corporate KYC Guidelines for Corporate Identification Program
  • Beneficiary KYC Individual Customer Identification Program
  • Employee KYC Individual Customer Identification Program
  • High Transcation Customer KYC Individual Customer Identification Program
  • Agent KYA Individual Customer Identification Program

10.7. Sanctions Policy:

Not limited to Sanction Specific Policies.

More information please contact current Compliance Officer: sergio@bitnexo.com