1. Introduction
BitMilesFX maintains a comprehensive Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program designed to prevent our services from being used for illicit activities. This policy outlines our commitment to regulatory compliance and our framework for detecting and preventing financial crimes.
Our AML/CTF Program is based on three fundamental pillars:
Prevention
- Robust customer verification processes
- Transaction monitoring systems
- Restricted services in high-risk jurisdictions
Detection
- Automated monitoring of unusual patterns
- Behavioral analysis algorithms
- Regular account reviews
Reporting
- Mandatory suspicious activity reports
- Regulatory compliance filings
- Internal escalation procedures
We comply with all applicable laws and regulations including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Financial Action Task Force (FATF) recommendations. Our program is regularly updated to address emerging threats and regulatory changes.
2. Risk-Based Approach
We employ a risk-based methodology to allocate compliance resources effectively. This approach allows us to focus our efforts where the risks of money laundering and terrorism financing are highest.
Risk factors we consider when evaluating customers and transactions:
Geographic Risk
High Risk: Sanctioned countries, FATF blacklist
Medium Risk: Jurisdictions with weak AML controls
Low Risk: FATF-compliant jurisdictions
Customer Risk
Politically Exposed Persons (PEPs)
Cash-intensive businesses
Salaried individuals with verifiable income
Product Risk
Anonymous transactions
High-value transactions
Low-value account transfers
Our risk assessment is dynamic and updated quarterly or when significant changes occur in a customer's profile, transaction patterns, or regulatory environment.
3. Customer Due Diligence
We implement rigorous Customer Due Diligence (CDD) procedures to verify the identity of our customers and understand the nature of their activities.
Our CDD process includes:
1
Identity Verification: Collecting government-issued ID, proof of address, and in some cases, biometric verification.
2
Beneficial Ownership: Identifying individuals who ultimately own or control legal entities (25%+ ownership).
3
Purpose of Account: Understanding the intended nature and purpose of the business relationship.
4
Source of Funds: Verifying the origin of funds used in transactions.
Individual Verification
- Full legal name and aliases
- Date and place of birth
- Residential address
- Government-issued photo ID
- Tax identification number
Entity Verification
- Certificate of incorporation
- Articles of association
- List of directors and shareholders
- Proof of registered address
- Business license
4. Enhanced Due Diligence
For higher-risk customers and transactions, we apply Enhanced Due Diligence (EDD) measures to mitigate potential money laundering and terrorism financing risks.
EDD is triggered in the following circumstances:
- Customers from high-risk jurisdictions
- Politically Exposed Persons (PEPs) and their associates
- Unusual or complex transaction patterns
- Customers involved in high-risk industries
- Transactions above regulatory thresholds
- Any situation where standard CDD is insufficient
Additional Documentation
- Source of wealth verification
- Bank references
- Professional references
- Evidence of business activities
Enhanced Monitoring
- Increased transaction scrutiny
- More frequent account reviews
- Ongoing verification of source of funds
- Senior management approval for transactions
For PEPs, we obtain senior management approval before establishing a business relationship and take reasonable measures to establish the source of wealth and funds.
5. Ongoing Monitoring
We conduct continuous monitoring of customer accounts and transactions to identify suspicious activities and ensure compliance with our AML/CTF policies.
Our monitoring systems detect:
Suspicious Patterns
- Structuring transactions to avoid thresholds
- Rapid movement of funds
- Transactions with high-risk jurisdictions
- Unusual account activity
Periodic Reviews
- Low-risk customers: Every 24 months
- Medium-risk customers: Every 12 months
- High-risk customers: Every 6 months
- Trigger-based reviews for activity changes
Our automated monitoring system analyzes transactions using advanced algorithms and machine learning. All alerts are reviewed by our compliance team within 24 hours of generation.
6. Suspicious Matter Reporting
We have established procedures for identifying, escalating, and reporting suspicious activities to the relevant financial intelligence units.
1
Detection: Automated systems and staff vigilance identify potentially suspicious activities.
2
Investigation: Our compliance team conducts a thorough investigation within 48 hours.
3
Decision: Senior Compliance Officer determines if a Suspicious Activity Report (SAR) is warranted.
4
Filing: SARs are filed electronically with FinCEN within 30 days of detection.
We maintain strict confidentiality regarding SAR filings:
- No disclosure to persons involved in the transaction
- Separate secure filing system for SAR documentation
- Restricted access to SAR information
- Prohibition against "tipping off" subjects of investigation
7. Record Keeping
We maintain comprehensive records to demonstrate compliance with AML/CTF regulations and to support investigations by law enforcement and regulatory authorities.
Our record retention policy:
Customer Identification
5 years after account closure
Transaction Records
5 years from transaction date
SAR Documentation
5 years from filing date
Records are maintained in secure, access-controlled electronic systems with regular backups. Physical documents are stored in fireproof cabinets with restricted access. All records are readily retrievable for regulatory examinations and law enforcement requests.
8. Staff Training
We provide comprehensive AML/CTF training to all relevant employees to ensure they understand their responsibilities and can effectively identify suspicious activities.
Training Program
- Annual mandatory training for all staff
- Role-specific training for compliance and frontline staff
- New hire training within 30 days of employment
- Updated training when regulations change
Curriculum
- Money laundering methods and typologies
- Terrorism financing indicators
- CDD/EDD procedures
- Suspicious activity recognition
- Reporting requirements and procedures
- Record keeping obligations
Training effectiveness is measured through:
- Post-training assessments with minimum 85% passing score
- Regular testing of suspicious activity recognition
- Quality assurance reviews of staff compliance
- Annual performance evaluations including AML compliance
9. Compliance Officer
Our AML Compliance Officer has the authority and responsibility to oversee the implementation and maintenance of our AML/CTF program.
Responsibilities of the AML Compliance Officer:
- Developing and updating AML/CTF policies and procedures
- Ensuring compliance with regulatory requirements
- Overseeing suspicious activity monitoring and reporting
- Managing the AML training program
- Conducting independent testing of the AML program
- Serving as the point of contact for regulatory inquiries
- Reporting directly to the Board of Directors on AML matters
The Compliance Officer maintains independence from business operations to ensure objective oversight. They have unrestricted access to all records, personnel, and systems necessary to perform their duties.
10. Policy Review
Our AML/CTF program is subject to regular independent testing and review to ensure its effectiveness and compliance with evolving regulatory requirements.
Independent Testing
- Conducted annually by qualified external auditors
- Comprehensive review of all program elements
- Assessment of program effectiveness
- Identification of deficiencies and recommendations
Management Review
- Quarterly reviews by senior management
- Assessment of emerging risks and trends
- Review of SAR filings and outcomes
- Evaluation of training effectiveness
- Formal report with findings and recommendations
- Board of Directors review and approval
- Implementation of corrective actions
- Program updates to address identified weaknesses
- Retesting of corrected deficiencies
Last Updated: October 15, 2024
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