Anti-Money Laundering and Know Your Customer Policy
It is important to note that the services we provide in relation to cryptocurrencies are unregulated in the United Kingdom.
Cryptocurrencies are not regulated by the FCA (and the UK’s money laundering authority)and on this basis they do not fall within the scope of the UK’s measures implementing the Payments Services Directive, the second Electric Money Directive or the third Money Laundering Directive.
Despite the fact that we are not required to be regulated by the FCA, the Cryptominal® AML/KYC Policy is designed to be as compliant with FCA regulation as Possible. We prevent money laundering by aiming to meet the UK legislation obligations, specifically referring to:
The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007).
We therefore have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate by sending the national crimes agency (NCA) a suspicious activity report (SAR);
The maintenance of appropriate records for the minimum prescribed periods;
Training and awareness for all relevant employees.
Cryptominal® PAD and POS
In order to mitigate risks of the Cryptominal® POS/PAD being used for illicit activities, we have implemented three levels of customer verification:
Monthly transaction limit: £1,000.00
Our merchant customers will be automatically Level1 verified when they complete an order for one of our Cryptominal® products, successfully conducted the order follow-up call with one of our support agents and subsequently submitted the on-boarding application form.
Monthly transaction limit: £10,000.00
In addition to fulfilling the level 1 verification procedures, merchant customers need to verify their address and identity. Addresses can be verified by letter or by physical premises inspection. Identity will be verified by ID document upload.
Monthly transaction limit: unlimited
We will undergo full KYC procedure. In order for merchant customers to become level 3 verified, they have to be level 2 verified and provide us with the following documents:
Share allotment document (which verifies all individuals with at least 20% share in the company).
Article of association which details the status of the company.
Proof of ID for every person with 20% or more equity in the business.
Proof of address for every person with 20% or more equity in the business.
All documents must be no older than 90 days. Any change of circumstances (such as address change etc.) has to be communicated to us and will trigger a new verification process.
We reserve the right at any time to reset the verification level where we see appropriate.
All ATMs operated by us have the following buy/sell limits:
For unverified customers:
For verified customers:
How to become verified:
When a customer wishes to use the Bitcoin ATM, s/he will be prompted to specify how much s/he wishes to purchase. If that amount falls outside the above specified transaction limits for unverified customers, the customer will be ask to verify him/herself. That will be done by providing a fingerprint, front and back of an ID (only Passports & Driver’s License accepted) and an E-mail address. Those records will be retained for future transactions. The verification process is instant and helps us meet our compliance requirements.
From the outset, the Cryptominal® Pad and POS will only be sold to established UK registered businesses. Private persons are not able and prohibited to purchase them. Distributers of our Cryptominal® will also exclusively sell to business customers.
Before a business can purchase from us, we will obtain relevant business and personal information from the customer. This will mostly be done via online order/application form and stored on a secure database. In case of cold door to door sales of Cryptominal®, the business information will be taken and verified in person. All data will be verified by our compliance officer. Furthermore, for merchants in high risk sectors such as gambling, we utilize a third party sanctions check which allows us to identify and blacklist any business customers with sanctioned persons exerting significant control over their business. In addition to that, we retain the right to request their AML/KYC policy. If their KYC/AML is either not existent or substandard, we will immediately cease any relations with that customer.
In addition to the aforementioned:
Our AML program is subjected to an internal audit at least annually.
We will Report and store certain customer and transaction records, as required.
We have sophisticated algorithms which will detect and flag unusual transactions
Enhanced Customer Due Diligence (ECDD)
If a client has been evaluated to be at a heightened risk to the company, we will begin the process of conducting ECDD and obtain senior management approval before establishing a relationship, and take reasonable measures to establish the source of wealth and the source of funds. Examples of higher risk customers/transactions include but not limited to:
Politically Exposed Person (PEP);
Customers who are positively identified to have adverse profiles on watch lists;
Customers located in high-risk locations;
Record keeping helps us understand the company over the entire relationship with the customer. Record keeping helps the company deal with its reporting obligations in submitting documents to the local financial intelligence unit for suspicions on money laundering or terrorist financing.
Any activity determined suspicious by us, will resort in the customer being blocked and will no longer be permitted to engage in any transactions via the Cryptominal®. Furthermore, an SAR will be filed and reported to the relevant authoritative department.
We are prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Where appropriate, we will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate. The official UK Government sanctions list (https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets) will be used to identify such persons. As a provider of virtual currency payment processing and exchange services, we are fully committed to conducting due diligence on our clients and ensuring that all applicable laws and regulations necessary to forestall and prevent money laundering.
Furthermore, we reserve the right to conduct enhanced due diligence on all clients given worldwide approved risk-based policies. Please note that we reserve the right to refuse a transaction or deny operation on a client or account at any time should suspicion arise that it may be connected to money laundering, criminal activity or any other predicate offense to money laundering. We will not enter into any business arrangement with anyone or group suspected of or directly involved in money laundering, or where funds have been sources or ends of an illegal activity.
In the event that we receive, during our request for documentation, deceptive documentation, contact details, business description or other false information, we will terminate the offending account. We are legally bound to report such misdemeanours to the relevant authorities, and as such the subject, business and its owners may be the subject to a criminal investigation.
Providing false, doctored, or deceptive documents is considered as fraud and will be treated as such. Tax Evasion and Fraud is a predicate offense to money laundering, and therefore, all assets derived from fraudulent transactions or suspicious activity may be seized and forfeited.
Cryptominal® Counter-Terrorism Financing Statement (CTF)
As part of the information that is collected during our verification and AML procedures, we conduct verification through worldwide databases. At the forefront, they will include global sanctions reports and government watch lists and rigorous screening processes. At any time, due to a requirement to satisfy any of the above verification methods, a client, business entity or any of the business entity owners or affiliates may be asked a specific document or piece of information to confirm their identity or provide additional information regarding any transaction, operations or even business dealings with certain individuals, institutions and dealings in geographical locations.
Should a situation arise where the nature of the business, geographical specific regulations or account activity fall in the scope of non-compliance in any applicable law or regulation, we will inform the client, business unit or any of the business owners or affiliates of the event and occurrence. For such instances, pre-verification and enhanced due diligence will be required prior to regaining active account status. In cases, where compliance is not achieved pursuing remediation measures, we will see fit to terminate the account and may report the event and surroundings to the applicable law enforcement and regulatory authorities.