Anti-Money Laundering Policy and Know Your Client Policy

The anti-money laundering and»Know your client» policy (hereinafter -«AML / KYC Policy») is designed to prevent and reduce the potential risks of Bitzlato being involved in any illegal activity.

In accordance with international and local regulations, Bitzlato implements effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption and bribery and to respond to any form of suspicious activity on the part of its Users.

The AML / KYC policy includes the Verification procedure, the presence in the company staff of an official responsible for compliance with AML standards, Transaction Monitoring, and Risk Assessment.

1. Verification procedure

One of the international standards for preventing illegal activities is Customer Due Diligence («CDD»). To this end, Bitzlato implements its own verification procedures in strict standards for counteracting the legalization of proceeds from crime and the»Know Your Client» procedure.

The Bitzlato Identification Procedure requires the User to provide Bitzlato with reliable, independent source documents, data or information (for example, a national ID card, international passport, bank statement, utility bill). For such purposes, Bitzlato reserves the right to collect User identification information in order to comply with the AML / KYC Policy.

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

 Bitzlato reserves the right to verify the identity of the User on an ongoing basis, especially when his identification information was changed or his activity seemed suspicious (unusual for a particular User). In addition, Bitzlato reserves the right to request up-to-date documents from Users, even if they have been authenticated in the past.

 After verifying the user’s identity, Bitzlato may waive potential legal liability in a situation where the company’s services are used to conduct illegal activities.

2. Compliance Officer

An AML Compliance Officer is a person duly authorized by Bitzlato whose responsibility is to ensure the effective implementation and enforcement of AML / KYC policies. The duty of such an official is to monitor all aspects of Bitzlato’s work in countering the legalization of proceeds of crime, including money laundering and terrorist financing, including, but not limited to the following methods:

• Collecting User Identity Information.
• Create and update internal policies and procedures to complete, review, submit, and store all reports and records required in accordance with applicable laws and regulations.
• Transaction monitoring and investigation of any significant deviations from normal activities.
• Implementation of a records’ management system for the appropriate storage and retrieval of documents, files, forms and magazines.
• Regular update of risk assessment.
• Providing law enforcement authorities with information necessary in accordance with applicable laws and regulations.

The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

3. Transaction Monitoring

Users are checked not only by verifying their identity, but, more importantly, by analysing their behaviour in transactions. Therefore, Bitzlato relies on data analysis as a tool for risk assessment and detection of suspicions. Bitzlato performs many compliance tasks, including data collection, filtering, record keeping, investigation management and reporting. System features include:

• Users daily checking for the existence of recognized»black
  lists» (for example, OFAC), aggregating transmissions by several data points, placing users on watch lists and refusing to provide services, opening cases for investigation where necessary, sending internal messages and filling out mandatory reports, if applicable.
• Manage affairs and documents.

Regarding the AML / KYC policy, Bitzlato will control all transactions and reserves the right to:

• ensure that suspicious transactions are reported to the appropriate law enforcement authorities through an AML officer;
• request from the User any additional information and documents in case of suspicious transactions;
• suspend or terminate the User’s account if Bitzlato has a reasonable suspicion that such User is involved in illegal activities.

The above list is not exhaustive, and the AML Compliance Officer will monitor user transactions daily to determine whether such transactions should be reported and considered suspicious or considered to be bona fide.

4.  Risk Assessment

Bitzlato in accordance with international requirements, applies the practice of risk assessment to prevent money laundering and the financing of terrorism.

By applying risk assessment practices to combat money laundering, Bitzlato ensures that measures to prevent or reduce money laundering and terrorist financing are commensurate with the risks identified.

Bitzlato cannot cooperate with customers which are residents  of  the following countries: Afghanistan, Albania, Algeria, Bangladesh, Bolivia, Burma (Myanmar), Burundi, Central African Republic, Guinea (Conakry), Cuba, North Korea (DPRK), Ghana, Guinea Bissau, Haiti, Iran, Iraq, Lebanon, Libya, Mali, Myanmar, Nicaragua, Pakistan, Qatar, Saudi Arabia, Somalia, South Sudan, Sudan, Syria, Tunisia, Uganda, United States of America (USA), Vanuatu, Venezuela, Yemen and Unrecognized territories with international law.