ANTI-MONEY LAUNDERING (AML) POLICY

Money laundering is the cover-up of illegal resources by converting them into cash or ostensibly legitimate investments.

As BITCI GLOBAL (“Company”), we take the issue of providing the best customer service to our Users very seriously, including giving great importance to account security. In order to prevent money laundering, we strictly follow AML (Anti-Money Laundering) Policy under any circumstances. In this context, the Anti-Money Laundering Policy (hereinafter referred to as “AML Policy”) outlines the procedures and mechanisms established by BITCI GLOBAL to prevent money laundering.

The purpose of the Anti-Money Laundering Policy is; with a risk-based approach, reducing the risks by evaluating the user, transactions and services of the BITCI GLOBAL, raising the level of awareness of the employees about the prevention of money laundering and financing of terrorism and obtaining information in this regard, and in this context, informing the Users that the Company carries out its activities on a legal basis.

Within the scope of this AML Policy, the User, to whom this AML Policy is implemented on and agrees and declares not to harm the Company’s activities, refers to the real persons who are members of the Platform (“Platform”) that can be accessed via www.bitci.com and those who benefit from the services offered on the Platform and therefore those who accept the matters in this AML Policy.

In accordance with the international legal norms and standards, BITCI GLOBAL has prepared its AML Policy and in this regard it has taken many measures such as verifying the identities of all Users to a reasonable extent, applying a risk-based approach to monitoring User transactions, notifying the relevant institutions and organizations of any suspicious transactions carried out by the Users within the framework of the current legislation and recording these transactions accordingly, and establishing the necessary organization to coordinate the implementation and applicability of the AML Policy at the Company.

Accordingly, BITCI GLOBAL follows the following policies:

Not to enter into business relations with criminals and/or terrorists;

Not to process transactions arising from criminal and/or terrorist activities;

Not to facilitate any action related to criminal and/or terrorist activities.

Risk Assessment

In line with the international requirements, BITCI GLOBAL adopts a risk-based approach to money laundering and financing of terrorism. Therefore, measures to prevent money laundering and financing of terrorism are commensurate with identified risks and allow the effective devotion of the resources. Resources are used on a priority basis and the greatest risks are given the highest consideration.

Since BITCI GLOBAL adopts a risk-based approach in monitoring the financial activities of its customers, in order to prevent money laundering and financing of terrorism, it may perform risk analysis with the following methods and monitor the relevant customers within the framework of the information obtained as a result of the risk analysis.

Users and transactions in the high-risk group are as follows:

If the total amount of a single cryptocurrency transaction or multiple linked transactions is equal to or more than EUR 100,000.00 and/or equivalent value in another currency and/or crypto assets of the same value;

If the total amount of a single cryptocurrency exchange or multiple linked exchanges is equal to or more than EUR 100,000.00 and/or equivalent value in another currency and/or crypto assets of the same value;

In cases where it required to report the suspicious transactions within the framework of current legislation;

If there is any doubt about the accuracy and adequacy of previously acquired identity information;

In cases of complex transaction that have the potential to hide third party beneficiaries;

Where the financial funds cannot be easily verified;

Unusual transactions without an economic or apparent legitimate purpose. 

Transaction Monitoring

Monitoring User’s transactions and analyzing the obtained data is also an important tool for risk assessment and detection of suspicious transactions. In case of suspicion of money laundering, BITCI GLOBAL has the right to monitor all transactions (customers in the high-risk group and transactions of those, complex and unusual transactions, transactions to and/or with the high-risk countries) and has the right to:

Report suspicious transactions to the relevant law enforcement authorities;

Request the User to submit additional information and documents;

Suspend or to terminate User’s account;

The list provided above is not an exhaustive one. The AML Policy Compliance Personnel monitors Users’ transactions on a daily basis and determines whether to report the customers and to consider them suspicious. 

Know Your Customer Policy (“KYC Policy”)

Detailed information about the Know Your Customer Policy can be found via the link https://www.bitci.com/legals/kyc/.

Verification Procedure

BITCI GLOBAL establishes its own procedures to determine anti-money laundering standards and compliance with its Know Your Customer (KYC) Policy.

BITCI GLOBAL Users have to complete a verification procedure (they have to present a government-approved identity document: passport or ID). For the purposes of the AML Policy, BITCI GLOBAL reserves the right to collect the identity information of its Users. This information is processed and securely stored in accordance with the BITCI GLOBAL Privacy Notice and User Agreement.

BITCI GLOBAL may request a second customer ID document (a bank receipt or electricity/water bill not longer than 3 (three) months that contains the User’s full name and real address).

After confirming the accuracy of the documents and information submitted by the User, BITCI GLOBAL reserves the right to request additional information about the User identified as dangerous or suspicious.

If the identity information of the User has been changed or his/her activities have been found suspicious, BITCI GLOBAL reserves the right to request updated documents from the Users, even if his/her identity has been verified before.

Reporting

Within the framework of the services provided by BITCI GLOBAL, in cases that raise suspicion regarding money laundering and financing of terrorism, in accordance with the current legislation and regardless of the amount, the transactions that are determined as suspicious as a result of the necessary investigations are reported to local or international authorities. The real persons who carried out the suspicious transaction and their legal representatives, the managers and personnel who do not comply with the obligation to report the suspicious transactions will be responsible for all kinds of legal, administrative and criminal sanctions.

Anti-Money Laundering Personnel

Anti-Money Laundering Personnel is a BITCI GLOBAL employee who is responsible to ensure the compliance with the AML Policy. Anti-Money Laundering Personnel is assigned to:

Collect Users’ identification information,

Establish and update internal policies and procedures for generating, reviewing, submitting and storing all necessary reports.

Monitor and analyze significant deviations from Users’ unusual activities,

Implement a record management system for recording and retrieving documents, files, forms and log session entries,

Regularly update the risk assessments.

Training, Updating and Internal Audit

With the personnel policy and procedures, BITCI GLOBAL fulfills all its obligations within the scope of training. In this context, it provides many trainings to its personnel, especially the Anti-Money Laundering Procedures, and ensures that this information is kept up-to-date.