Anti-Money Laundering (AML) Policy

1. Introduction

Bitnank is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This AML Policy outlines our procedures to prevent, detect, and report money laundering and terrorist financing activities.

We comply with applicable AML/CTF laws and regulations in all jurisdictions where we operate. Our commitment extends to implementing robust systems and controls to identify and mitigate financial crime risks.

2. Policy Statement

Bitnank has zero tolerance for money laundering, terrorist financing, and any form of financial crime. We are committed to:

• Preventing our platform from being used for money laundering or terrorist financing
• Implementing effective customer due diligence procedures
• Monitoring and reporting suspicious activities
• Cooperating fully with law enforcement and regulatory authorities
• Maintaining comprehensive records of transactions and customer identification
• Training our staff on AML/CTF requirements
• Conducting regular risk assessments and audits

3. Know Your Customer (KYC) Requirements

3.1 Customer Identification

All users must complete our KYC verification process before accessing full platform features. We collect and verify:

• Full legal name (as it appears on official documents)
• Date of birth
• Residential address with proof of address
• Government-issued identification (passport, driver's license, or national ID)
• Photograph or selfie for identity verification
• Phone number and email address
• Source of funds information (for large transactions)
• Occupation and employment details (when required)

3.2 Verification Levels

• Level 1 (Basic): Email and phone verification - Limited transaction amounts
• Level 2 (Standard): Full KYC with ID and address verification - Higher transaction limits
• Level 3 (Enhanced): Additional documentation for high-volume traders - Unlimited transactions

3.3 Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for high-risk customers, including:

• Politically Exposed Persons (PEPs)
• High-net-worth individuals
• Users from high-risk jurisdictions
• Customers with unusual transaction patterns
• Business accounts and corporate entities

3.4 Ongoing Monitoring

KYC verification is not a one-time process. We continuously monitor customer accounts and may request updated documentation to ensure information remains current and accurate.

4. Transaction Monitoring

4.1 Automated Monitoring Systems

We employ sophisticated automated systems to monitor all transactions in real-time for suspicious activities, including:

• Unusual transaction patterns or volumes
• Rapid movement of funds
• Structuring or layering of transactions
• Transactions involving high-risk jurisdictions
• Significant deviations from normal user behavior
• Transactions with no apparent economic purpose
• Multiple transactions just below reporting thresholds

4.2 Transaction Limits

We implement transaction limits based on verification levels:

• Daily deposit limits
• Daily withdrawal limits
• Per-transaction limits
• Monthly cumulative limits

4.3 High-Risk Transactions

Transactions flagged as high-risk may be subject to:

• Temporary holds pending investigation
• Additional verification requirements
• Manual review by our compliance team
• Enhanced documentation requests

5. Suspicious Activity Reporting

5.1 Identification of Suspicious Activities

We actively identify and investigate activities that may indicate money laundering or terrorist financing, including:

• Transactions inconsistent with customer profile
• Unexplained or unusual sources of funds
• Complex or unusual transaction patterns
• Attempts to avoid identification or reporting requirements
• Use of multiple accounts by the same individual
• Frequent deposits followed by immediate withdrawals
• Transactions involving known criminal entities
• Use of stolen or compromised payment methods

5.2 Reporting Obligations

When suspicious activity is detected, we:

• Document all relevant information
• Conduct internal investigation
• File Suspicious Activity Reports (SARs) with relevant authorities
• Preserve all related records and evidence
• Cooperate fully with law enforcement investigations

5.3 Confidentiality

We do not disclose to customers that suspicious activity reports have been filed or that an investigation is underway, as required by law.

6. Prohibited Activities and Jurisdictions

6.1 Prohibited Transactions

Bitnank strictly prohibits the following activities:

• Money laundering and terrorist financing
• Transactions involving proceeds of crime
• Trading in illegal goods or services
• Sanctions violations
• Fraud and financial crimes
• Tax evasion schemes
• Pyramid schemes or Ponzi schemes
• Unlicensed money transmission

6.2 Restricted Jurisdictions

We do not provide services to users from jurisdictions identified as high-risk for money laundering or terrorist financing, including:

• Countries on FATF (Financial Action Task Force) blacklists
• OFAC (Office of Foreign Assets Control) sanctioned countries
• UN Security Council sanctioned territories
• Jurisdictions with inadequate AML/CTF frameworks

6.3 Sanctions Screening

We screen all users and transactions against:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Sanctions Lists
• EU Consolidated Financial Sanctions List
• Other relevant sanctions and watch lists

7. Record Keeping

7.1 Documentation Requirements

We maintain comprehensive records of:

• Customer identification and verification documents
• Transaction records and details
• Communications with customers
• Internal investigations and reviews
• Suspicious activity reports
• Risk assessments

7.2 Retention Period

• Customer identification records: Minimum 5 years after account closure
• Transaction records: Minimum 5 years after transaction completion
• Investigation records: Minimum 7 years
• Suspicious activity documentation: As required by law (typically 5-7 years)

7.3 Data Security

All records are stored securely with restricted access, encrypted storage, and regular backups to ensure integrity and availability for regulatory requests.

8. Risk Assessment

8.1 Risk-Based Approach

We adopt a risk-based approach to AML/CTF compliance, assessing risks based on:

• Customer Risk: Type of customer, verification level, geographic location
• Product Risk: Type of service, transaction complexity, value
• Geographic Risk: Jurisdictions involved in transactions
• Delivery Channel Risk: Method of service delivery

8.2 Regular Reviews

We conduct regular risk assessments to:

• Identify emerging risks and threats
• Update our AML/CTF procedures
• Enhance our monitoring systems
• Ensure compliance with evolving regulations

9. Staff Training and Awareness

All Bitnank employees receive comprehensive AML/CTF training, including:

• Recognition of money laundering and terrorist financing indicators
• KYC and customer due diligence procedures
• Transaction monitoring and reporting requirements
• Regulatory obligations and legal consequences
• Internal policies and procedures
• Regular updates on emerging threats and typologies

10. Compliance Officer

Bitnank has designated a Compliance Officer responsible for:

• Overseeing AML/CTF program implementation
• Ensuring regulatory compliance
• Reviewing and investigating suspicious activities
• Filing required reports with authorities
• Maintaining relationships with regulatory bodies
• Coordinating staff training programs
• Conducting internal audits and reviews

11. Cooperation with Authorities

Bitnank maintains a cooperative relationship with law enforcement and regulatory authorities:

• Responding promptly to information requests
• Providing requested documentation and records
• Assisting in investigations
• Complying with court orders and subpoenas
• Implementing sanctions and enforcement actions
• Participating in industry information sharing (where permitted)

12. Consequences of Non-Compliance

Users who violate this AML Policy or engage in prohibited activities may face:

• Immediate account suspension or termination
• Freezing of funds pending investigation
• Reporting to law enforcement authorities
• Legal action and prosecution
• Forfeiture of assets involved in illegal activities
• Permanent ban from the platform

13. Policy Updates

This AML Policy is reviewed and updated regularly to reflect:

• Changes in applicable laws and regulations
• Emerging money laundering and terrorist financing risks
• Best practices and industry standards
• Recommendations from regulatory authorities
• Results of internal audits and risk assessments

14. Reporting Suspicious Activity

If you become aware of any suspicious activities on our platform, please report them immediately: