Bitliberty LLC., company number 4062001331609, registered at: Republic Of Costa Rica, San Jose- San Jose Mata Redonda, Neighborhood Las Vegas, Blue Building Diagonal To La Salle High School (“Company”) has developed and formally approved this AML/CFT Policy to comply with the best AML/CFT practices. This AML/CFT Policy is supported by adequate and effective internal policies, procedures and controls to manage and mitigate money laundering and terrorist financing risks in Company’s business operations.
The purpose of this policy is to introduce the obligatory measures and other obligations stipulated by the relevant legislation.
When Customer first uses Company's services, this policy is treated as having been accepted by such Customer
Company has implemented various AML/CFT measures including but not limited to:
The principles of identifying and assessing the risk of money laundering and terrorist financing are set forth in Company’s internal procedure and contains the following:
Company carries out Customer, its representatives identification, verification (KYC) in line with the internal procedures and governing law. Customer is obliged to provide proper information and documents as required by the Company.
If Customer occurs to be PEP, PEP family member, Close associate of PEP, Customer shall inform Company thereof prior to using Company’s service. If Customer acquires the PEP, PEP family member, Close associate of PEP status while using Company services, she/he must notify Company right away.
Customer-legal entity shall provide Company with the identification information of its Ultimate Beneficial Owners and support their verification by Company.
Company applies Customer identification procedures and due diligence measures:
The documents and information provided by Customers shall be correct, accurate and complete. In case of such information/documents change, Customer shall immediately inform Company of such update.
Company carries out simplified/enhanced Customer identification and Due Diligence procedures depending on risks associated with Customer. Riskiness criteria are set out by the Company in its internal guidelines, procedures.
Company monitors thoroughly on an ongoing basis the compliance of the internal and regulatory rules and procedures with the relevant laws and regulations considering each case and each Customer.
All Customers’, their representatives’ personal information and documents collected in connection with the KYC procedure will be used, stored, and protected according to Company’s Privacy Policy and in full compliance with the relevant legislation.
Company monitors diligently transactions that take place when using Company’s services looking for suspicious activity and unusual behaviors. For this purpose, Company has implemented thorough risk categorization.
Transactions are analyzed by the Company's team and evaluated, whether they do not provide significant AML/CTF risks, or if they need to be clarified with Customer with additional details / verification.
When Customer’s transactions are “flagged” as suspicious or unusual compared to Customer profile, Company’s AML/CTF verification duties increase correspondingly. In such situations, Company requires additional information/ documentation proving transactions explanation, source of funds, living address, information about the amount of incomes etc.
In cases itemized in Company’s procedures and/or governing law, Company is entitled to perform an account blockade.
Company shall report suspicious transactions to appropriate authorities as required by the law.
In case Company’s team evaluates information received from Customer not clarifying the doubts or risks, Company will be obliged to disable the services.
Keeping records is important for monitoring and all records must be kept by the Company within the period set forth in its internal regulations and by the law
Company is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Company carries out screening against sanctions lists created by the United Nations, OFAC, European Union etc
“AML/CFT” – means anti-money laundering - a set of activities, procedures, and regulations designed to prevent criminal activities related to money laundering (AML), and counteracting the financing of terrorism (CFT) - a set of activities, procedures and regulations created in order to prevent criminal activities related to terrorism
“Close associate of PEP”- a natural person who is the beneficial owner of a legal person, an organizational unit without legal personality or a trust jointly with PEP or having other close relationships with it related to the conducted business activity, as well as a natural person who is the sole beneficial owner of legal persons, organizational units without legal personality or a trust, known to have been created for the purpose of obtaining an actual benefit by the PEP.
“Customer” means a natural person, legal person, or organizational unit without legal personality, to which/whom Company provides services or for which/whom it performs activities falling within the scope of its professional activity
“Due diligence” – means an investigation, audit, or review performed to confirm the facts of a matter under consideration.
“Business relations” - the relationship of Company with Customer related to the professional activities of Company, which at the time of its establishment show the characteristic of permanence.
“Financing terrorism” and “money laundering” have meaning assigned to them by the proper legislation.
“PEP” – politically exposed person being an individual who holds a significant position or public office.
“PEP family member” - spouse or cohabiting person, child of PEP or his spouse or cohabiting person, parents.
“Ultimate Beneficial Owner” - a natural person or natural persons exercising direct or indirect control over Customer through their powers that result from legal or factual circumstances, enabling them to exert a decisive influence on the activities or actions undertaken by Customer or natural person, or natural persons, on behalf of whose business relations are established or an occasional transaction is carried out.