The purpose of the BITMONSTERS’ Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is to identify, prevent and mitigate possible risks of BITMONSTERS being involved in illegal activity any kind.

In conformity with international and local regulations, BITMONSTERS has implemented effective internal procedures  and mechanisms to prevent money laundering, terrorism financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to react correspondingly in case of any form of suspicious activity from its Users.

AML/KYC Policy includes User Verification procedures, AML Compliance Officer, Monitoring Transactions, and Risk Assessment.

Customer due diligence (“CDD”) is one of the international standards for preventing illegal activity. With that in mind, BITMONSTERS has implemented its own verification procedures within the rigorous standards of anti-money laundering and “Know Your Customer” procedures.

The BITMONSTERS’ identification procedure requires the User to provide BITMONSTERS with reliable, independent source documents, data or information (for example, a national ID card, an international passport, a bank statement, or an utility bill). Thus, BITMONSTERS reserves the right to collect the User’s identification information for the purpose of AML / KYC Policy compliance.

BITMONSTERS will take steps to confirm the authenticity of documents and information provided by Users. All legal methods for double verification of identification information will be used, and BITMONSTERS reserves the right to investigate the cases of certain Users whose identities have been identified as dangerous or suspicious.

BITMONSTERS reserves the right to verify the identities of its Users on an ongoing basis, especially when their identification information has been changed or their activities appear suspicious (unusual for a particular User). Besides, BITMONSTERS reserves the right to request from Users providing their current documents, even if they have been authenticated in the past.

Information about the User’s identification will be collected, stored, shared and protected   in strict accordance with the BITMONSTERS Privacy Policy and relevant rules.

After having confirmed the User’s identity, BITMONSTERS may refuse from potential legal liability in the situation where the company’s services are used for carrying out illegal activities.

The AML Compliance Officer is the person duly authorized by BITMONSTERS, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of BITMONSTERS’s anti-money laundering and anti-terrorism financing activities, including but not limited to the following methods:

  • collecting Users’ identification information;
  • establishing and updating internal policies and procedures for completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
  • monitoring transactions and investigating any significant deviations from normal activity;
  • implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
  • regular risk assessment updating;
  • providing law – enforcement authorities  with information as required under the applicable laws and regulations.

The AML Compliance Officer is entitled to liaison with law – enforcement authorities, which are involved in prevention of money laundering, terrorism financing and other illegal activities.

Users are verified not only through their identity verification, but, more importantly, through analyzing their transactional patterns. Therefore, BITMONSTERS relies on data analysis as a risk-assessment and suspicion detection tool. BITMONSTERS performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  • Daily check of Users against the recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  • Case and document management.

 

What concerns AML/KYC Policy, BITMONSTERS will monitor all transactions and it reserves the right to:

  • ensure that transactions of suspicious nature are reported to the relevant law – enforcement authorities through the AML Compliance Officer;
  • request from the User providing any additional information and documents in case of any suspicious transactions;
  • suspend or terminate the User’s Account when BITMONSTERS has a suspicion that such User is engaged in any illegal activity.

However, the above list is not at all exhaustive, and the AML Compliance Officer will monitor Users’ transactions on a daily basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide ones.

BITMONSTERS, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorism financing.

Applying a risk-based approach, BITMONSTERS is able to ensure that measures aimed at prevention or mitigating money laundering and terrorism financing are commensurate to the identified risks. This will allow taking measures the most effective way. The underlying principle is that measures shall be taken in accordance with the priorities to pay the maximum attention to the highest risks.