Last revised: July 5, 2022
Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicion.
To prevent, detect and combat money laundering and terrorist financing activities and suspicious financial transactions and activities, this AML/KYC Policy was issued based on Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, and US FINRA on the Prevention of Money Laundering and Terrorist Financing. These regulations, together with requirements, rules, and industry guidance (including but not limiting AMLD and FATF), form the cornerstone of our AML/CTF obligations and outline the offenses and penalties for failing to comply.
Specific provisions of our policy are confidential and for internal use only. So, please get in touch with the iBBT AML/KYC Policy, which directly concerns you and affects the use of our services.
This Anti-money Laundering Policy (now called “AML Policy”) outlines the procedures and mechanisms used by iBBT to prevent money laundering. iBBT adheres to the following policies:
not entering into business relationships with criminals or terrorists;
not processing transactions that result from criminal or terrorist activities;
not facilitating any transactions related to criminal or terrorist activities.
Transaction – customer asset management. The transaction is performed through the customer account.
A risk Client Profile illustrates the risks and threats organizations encounter when working with the Client. This may include the probability of negative consequences, potential costs plan, and level of violation for each risk. It is important to be proactive regarding risk management systems. Some risks can be minimized if adequately taken into account. In addition, compliance with risk accounting requirements ensures the company and its employees comply with regulatory and ethical processes.
Accounting system – the company’s internal electronic system for storing customer information.
Proof address – utility bill, property tax receipt, etc.
The Service Provider’s activities description:
The Service Provider offers services of exchanging virtual currencies against virtual currencies, a virtual currency against a fiat currency, and vice versa. The Service Provider is subject to authorization by the US FINRA.
The MB shall appoint a CO to monitor the compliance with the Rules & relevant laws, compile & keep updated the data regarding countries with low tax risk, high and low risk of Money Laundering and Terrorist Financing and economic activities, instruct the Representatives, report to the MB on compliance with the Rules, process the data on suspicious activities, report to the US FINRA on events of suspected ML or TF, respond to US FINRA. Inquiries; make proposals on remedying deficiencies.
A department can perform tasks of the CO
Application of due diligence measures
The Service Provider shall determine and take due diligence (DD) measures using results of conducted risk assessment/provisions of national risk assessment published on the web page of the US FINRA.
DD measures shall include the following procedures:
Identifying the Client and verifying its identity, including e-identifying, Identifying and verifying the Client’s representative and the right of representation, Identifying the Client’s Beneficial Owner, Assessing and obtaining information on the purpose of the Business Relationship and the Transaction, Conducting ongoing DD on the Client’s business to ensure the Transactions being carried out are consistent with the Provider of service’s knowledge of the Client and its source of funds, Obtaining information whether the Client is a PEP or PEP’s family member / close associate.
To comply with the DD obligation, the Representatives shall have the right and duty to:
Request appropriate identity documents to identify the Client and its representatives, request Proof of address, request documents and information regarding the Client’s activities / legal origin of funds, request information about Beneficial Owners of a legal person, screen the risk profile of the Client/Transaction, assess the risk whether the Client or another person linked with the Transaction may become involved in ML or TF, re-identify the Client / its representative, in case of any doubts regarding the correctness of the information, refuse to participate in or carry out the Transaction if there is any suspicion that the Transaction is linked with ML or TF, or that the Client / another person connected with the Transaction could be involved in ML or TF. The continuously applied DD measures’ objective is to ensure ongoing client and transaction monitoring.
Updated data shall be recorded in the Provider of service’s Client database.
Identification of a person:
Upon implementing DD measures, the following person shall be identified:
Client – a natural or legal person, Representative of the Client – an individual authorized to act on behalf of the Client; · Beneficial Owner of the Client, PEP – if the PEP is the Client or a person connected with the Client.
Upon establishing the relationship with the Client and when carrying out a Transaction, the Service Provider shall identify and verify the Client while being present at the same place as the Client or by using information technology means.
For identification of a Client and verification of the identity of a Client by using information technology means, the Provider of service shall use:
an ID document issued for digital identification;
a driving license/learning license;
Another electronic identification system within the meaning of the Regulation (EU). If the Client is a foreign national, the identity document issued by the competent authority of the foreign country is also used simultaneously.
Documents that can be used for identification:
Personal ID card (whether ID card, e-resident card, or residence permit card), passport, diplomatic passport, or driving license/learning license.
Legal person and their passive legal capacity shall be identified and verified based on an extract of a registry card of the commercial register; foreign legal persons shall be determined based on an extract of the relevant register / a transcript of the registration certificate / a matching document issued not earlier than six months before submission.
The following data shall be recorded:
For a natural person:
Name of the Client
Personal identification code (in case of absence, the date, and place of birth and place of residence)
Information regarding identification and verification of the right of representation
For a legal person:
Name of the Client
Registry code (or registration number and registration date) of the Client
Names and authorizations of members of the Management Board or the head of the branch, or the other relevant body
Register of the shareholders
Certificate of incorporation
*If you have a European company and open register, please send only a certificate of incorporation
The verification procedure on the iBBT platform is mandatory for all new and existing Clients to use the platform’s services.
iBBT shall establish its procedures for determining compliance with the anti-money laundering standards and Know Your Customer (KYC) policy.
iBBT may also request a second Customer identification document: a bank statement or utility bill no older than three months, which includes the Customer’s full name and current address.
iBBT shall verify the authenticity of documents and information provided by Customers and reserves the right to request additional information on Customers who have been identified as dangerous or suspicious.
Suppose the Customer’s identification information has been changed or their activity appears suspicious. iBBT is entitled to request updated documents from the Customer, even if they have been authenticated in the past.
Anti-Money Laundering Officer
The Anti-Money Laundering Officer is an iBBT employee who is responsible for ensuring compliance with the AML Policy, such as:
Collection of Customers’ identity information;
establish and update internal policies and procedures for creating, reviewing, submitting, and storing all reports required under existing laws and regulations;
transactions monitoring and analysis of any significant deviations from the Customers’ usual activities;
the introduction of a records management system for storing and retrieving documents, files, forms, and logs;
regularly update risk assessments.
An Anti-Money Laundering Officer has the right to engage with law enforcement agencies that lead with the prevention of money laundering, financing of terrorism, and other illegal activities.
To screen out suspicious or unusual Transactions and the purpose and actual substance of a Transaction, the Representative can take the following actions:
Ask the Client to provide (additional) information about the professional or economic activities, ask the Client explanations about the reasons for the Transaction and documents evidencing the origin of the assets or source of wealth, being particularly attentive to Transactions, which are linked with natural or legal persons, whose country of origin is a state, wherefrom it is challenging to receive information about the Client or transactions with persons, who originate from such conditions, which do not contribute in prevention of ML sufficiently.
A request is sent to the Client if it is necessary to obtain additional documents or information on the source of virtual assets.
Monitoring the Customer’s transactions and analyzing the obtained data is also a tool for risk assessment and detecting suspicious transactions. If money laundering is suspected, iBBT shall monitor all transactions and reserves the right to:
reporting suspicious transactions to the relevant law enforcement agencies;
request the Customer to provide any additional information and documents;
suspend or terminate the Customer’s Account.
The above list is incomplete. The AML Policy Compliance Officer monitors the Customers’ transactions daily to determine whether to report them or treat them as suspicious.
Per international requirements, iBBT applies a risk-based approach to anti-money laundering and financing of terrorism. Thus, measures aimed at the prevention of money laundering and financing of terrorism are commensurate with the identified risks, allowing resources to be effectively dedicated. Accordingly, resources are prioritized; the most significant attention is given to the most significant risks.
The Representative will establish a client’s risk profile based on information gathered under the Rules.
For a search regarding international sanctions imposed against a person or country, please refer to: https://www.sanctionsmap.eu/#/main or https://sanctionssearch.ofac.treas.gov/
Assessment of risk profile of natural persons:
When establishing the risk category of a Client being a natural person, the Client’s country of residence, the Transaction’s beneficiaries, the region where the Client operates, and the status of PEP shall be considered.
Assessment of risk profile of legal persons:
When establishing the risk category of a legal person, the assessment shall be based on the country of location of the legal person, its area of activity, the transparency of ownership structure, and the management.
Suspicious and unusual Transactions and Transactions with characteristics of ML and TF.
The Representative shall decide whether a Transaction is unusual regarding the entire information known about the Client and the Transaction.
After looking over a Transaction, it is necessary to figure out whether the unusual circumstance or change is understandable / whether the Transaction has characteristics pointing to ML or TF.
Any Transactions and activities of Clients, which have no apparent economic or legal reason, and which cannot be considered a regular economic activity of a Client shall be regarded as suspicious.
Among other aspects, particular attention must be paid to the following Transactions/circumstances:
Client makes single or consecutive large Transactions outside the schedule; a third person makes payments on behalf of the Client, any of the characteristics of suspicious transactions as provided by guidelines of the US FINRA.
In all the cases referred to above, the Client will need an explanation and necessary documents showing the legal origin of the funds.
Before beginning cooperation with a client, an initial verification of clients shall take place, the questionnaire form is to be filled out on the site, and the identification document (passport, ID card) will be provided. Passports and ID cards shall be checked via the sources described in the procedure.
The Transaction may be carried out only with the consent of the MB if:
The Client does not have sufficient authorizations to carry out the Transaction, or the authorizations are unclear, the Client’s need to carry out the Transaction has not been reasonably justified, the management, ownership and control structure of the Client being a legal person is unclear and/or it is structured in an unreasonably complicated way from the economic point of view, or it has changed frequently without justification, Economic activities of a legal person or its accounting or payment practices are not transparent, the Client may be a fictitious company or a fictitious person, The Beneficial Owner of the Client being legal person cannot be established, The Client being a legal person uses an agent or another legal person as its representative without explicit authorizations (i.e. during pre-contract negotiations),The Client or the representative of the Client refuses to provide information for the purposes of establishing the substance of the Transactions and assessment of the risks, The Client has not presented sufficient data or documents to prove legal origin of the assets and funds, after having been asked to do so, The Client, the Beneficial Owner of a Client being a legal person, or another person associated with the Client is or has been linked with organized crime, ML or TF, The Client, the Beneficial Owner of a Client being a legal person, or another person associated with the Client is or has been linked with traditional sources of income of organized crime, International Sanctions are being applied against the Client, the Beneficial Owner of a Client being a legal person, or another person associated with the Client, The Client has nominee shareholders or shares in bearer form.
If you have any questions about this KYC/AML Policy, the practices of this site, or your dealings with this site, don’t hesitate to contact us at support(at)ibbt.io.