AML and KYC Policy

Anti-Money Laundering Policy

1. Money laundering involves concealing the origin of funds and/or the identity of parties transferring or receiving them. We strongly oppose money laundering and take extensive measures designed to ensure that our services are used by legitimate Users only. Our Anti-Money laundering policy and all its practical implications are aimed at combating money laundering by working to expose any such attempt, preventing its completion and taking legal action against the parties involved in said attempt. As elaborated on further down, we make certain to allocate adequate resources so that no money laundering attempt can ever go unnoticed.

2. Advanced Security System
2.1. Our platform is equipped with anti-money laundering security systems. The screening process of all users undergoes upon creating a new user account and to ensure that all users are genuine individuals on using our online Service in order to engage in legitimate activities using funds the origins of which are verified and traceable.

3. KYC procedures

3.1. We take steps designed to ensure that users using our Service are genuine individuals. Anyone creating a new trading account is required to provide proof of identification as well as documentation showing that they truly reside at the address the details of which they provide us with.
3.2. Required documents should be uploaded to by client to the appropriate section of user account. All copies of documents should be:

3.2.1. Clear, readable, without blur;
3.2.2. Without crossed out, painted over or erased information;
3.2.3. No pictures or copies of pictures, no pictures of monitor;
3.2.4. Taken with flash off;
3.2.5. If document contains handwritten signature, it should be clear enough to be compared with signature on person’s ID.

3.3. E-mail address and phone number of the client are also verified.

3.4. Upon registration the account of private individual, we ask that the following documentation be provided:

3.4.1. Proof of Identity – Front and back colored copy of a valid ID card, (can be a passport, ID or a driver’s license) showing all 4 corners of the document, and the document must be valid for at least next six months.In case if the country of residence and country that issued ID are different, and if residence is temporary, also needs to be provided a copy of legal right to remain in the country of residence (e.g. visa).
3.4.2. Proof of Residency – Official document from last 6 months, addressed to the place of residence of the client.

Accepted types of documents:

3.4.2.1. Utility bill (gas/water/electricity/phone/internet/TV/mobile)
3.4.2.2. Bank statement
3.4.2.3. Letter or other document from state authorities (tax office, municipality)
It must contain on one page:
3.4.2.4. Full name and logo of issuing institution
3.4.2.5. Full name of recipient of the document
3.4.2.6. Address of recipient of the document (being the residence address of the client)

                        3.4.3. For possibility to receive Wire deposits – selfie with Proof of Identity. Requirements for selfie:

                       3.4.3.1. Colored picture of good quality;
                       3.4.3.2. Person is looking at the camera, no red eyes;
                       3.4.3.3. No sunglasses or other items that hide parts of face;
                       3.4.3.4. Information in document is readable.

                        3.4.4. Upon depositing funds into an account, we ask that the following documentation be provided:

3.4.4.1. Copy of the card – Must be provided for any new credit/debit card that is used to make a deposit to the account. Front side colored copy, showing only the last 4 digits and card holder name. Back side colored copy, showing only last 4 card digits;
3.4.4.2. Signed Declaration of deposit. It may be sign in handwritten or by digital signature;к

3.5. Upon registration the account of corporate client, we ask that the following documentation be provided:

3.5.1. Certificate of Incorporation, that formalizes creation of the company;
3.5.2. Extract from Business Registry (maximum 6 months old), that shows that company is officially registered and operating;
3.5.3. Memorandum and Articles of Association, or other document, stat defines company’s structure, governance and distribution of powers, activities, structure of capital;
3.5.4. Bank statement from current banking institution (for a period of last 3 months);
3.5.5. Official list of Directors/Shareholders/Authorised Signatories – must contain names of the director, structure of management, members of the management board or other body replacing the management board;
3.5.6. Documents on Director/General manager (CV);
3.5.7. Documents for Authorised Signatories for account with us (Proof of identity, Proof of residence, Power of attorney;
3.5.8. Company group structure, information on shareholders and ultimate beneficiary, in case if company was created less then 3 months before registration at our platform – information and evidence of source of wealth and source of funds, used to form equity of the company);
3.5.9. Business license (if applicable);
3.5.10. Tax payer information;
3.5.11. Proof of domain ownership of official website;
3.5.12. Internal decision (Order, Minutes of committee) that authorises opening crypto currency account with Bit2Bit OU.

Additional information might be requested to explain business activities and purpose of planned business relationship.

All signatures must be hand written.

Public documents issued in a foreign country must be legalised or confirmed with a certificate (an Apostille), i.e. an internationally recognised official certification of the authenticity of the document has been issued for use of an official document issued in one country in another country, whilst legalisation and the attachment of an Apostille does not confirm that the information in the document is true.

4.3. Evidence of Source of funds of private individuals is required for deposits over 30 000 Euro or in equivalent. Depending on individual cases, Compliance might request to provide evidence for deposits over 9 000 Euro or in equivalent. Evidence of Source of funds for corporate clients is required for all deposits.

Evidence for private individuals includes:

4.3.1. Bank statement, that shows that client owns incoming or accumulated funds, that will be used for deposit to Bitobit account. Source of those funds must be clear from the statement. If funds are transferred from another account of the client, for that account statement should also be provided, and all requirements to clarity of origin of money apply to it.
4.3.2. Document that proves the source of income.

          4.4. Additional verification of identity and ID with special service is required  for deposits over 30 000 Euro or in equivalent.

         4.5. Additional documents may be required such as Proof of wire transfer or crypto transfer;

          4.6. Personal call to the client.

5. Upon withdraw funds from the account (either through Withdrawal request or crypto request) a client must:

5.1. Verify his personal mobile phone;
5.2. Sign Declaration of crypto withdrawal (in case of crypto request).The KYC and AML processes are conducted by our Compliance team and in accordance with EU and Estonian Law.

6. Documents that contain client’s handwriting should be filled in by the person themselves and no fields can be empty or contain wrong information.

7. In case of enhanced KYC procedure, or a suspicion of any kind of fraudulent activity, user has to complete an additional verification.

8. In case if there is a need to change verified e-mail of the user, user has to provide selfie with an ID and a written application to change verification details.

9. Bank Accounts and Money Transfers. Not only personal details are verified, bank account details, as well as credit card or any other, web sources, money transferring means used also undergo a screening process. We make it impossible to use our services with a dubious bank account and refrain from processing money transfer requests when the path of funds is unclear.