Anti Money Laundering & Counter Terrorist Financing Policy

Introduction

Bitconvert Ltd. (TheChange or the Company) and its board of directors is fully committed to complete compliance with all applicable anti-money laundering and the financing of terrorism laws and regulations.

Every officer, director, employee and associated person of the Company is responsible for assisting in the Company’s efforts to detect, deter,  prevent and report money laundering and other activities intended to facilitate the funding of terrorism or criminal activities through its services.

Obligations

​The principle requirements, obligations and penalties, on which the Company’s systems and controls are based, derive from the European Union Anti Money Laundering Directives which have been transposed in the Malta Prevention of Money Laundering Act (Cap.373) and the Prevention of Money Laundering and Funding of Terrorism Regulations (Cap.373.01) and FIAU Implementing Procedures Part 1 and Part 2 (FIAU Implementing Procedures – Application of Anti Money Laundering and Counter Funding of Terrorism Obligations to the Virtual Financial Assets Sector). Our obligations are also based on The Virtual Financial Assets Act (Cap.590).

The Company has instituted measures in order to:

  • comply with rules and regulations regarding customer identification, monitoring and record-keeping;
  • detect and analyze suspicious activity and if required report such activity, and
  • develop, update and execute internal policies, procedures and controls.

Apart from the above measures, the Company has set up internal procedures concerning the following basic principles:

Risk Assessment

​In determining the level of Customer Due Diligence, the Company identifies and assesses the ML/FT risk in relation to a customer or a particular transaction

Assessing and understanding client-related money laundering and terrorist financing risks is a critical component of our Business Risk Assessment framework, which helps us to mitigate and manage risk in line with our financial crime risk appetite.

The primary objective of risk segmenting our client base is to conduct appropriate due diligence and to ensure a comprehensive client profile is in place to enable the comparison of the results of ongoing monitoring and identify any discrepancies.

Customer Identification and Verification

​One of the initial obligations of The Change is that it must clearly identify and verify its customers prior to providing them access to its services.

The identity of the prospective customer will be established by obtaining sufficient customer data/documents/information (which would also include, where applicable, data pertaining to beneficial owners) through the production of official documents and verify such data/document/information against independent sources.

In the course of its verification process, which would include the screening of customers against internationally issued watch lists, The Change, has the right to accept or refuse any prospective customer request.

Furthermore, during the customer relationship, The Change has a right to update its records by requesting verification of the data already submitted or to request additional information also in relation to the source of wealth and source of funds.

Training

The training of employees plays a vital role in the effectiveness of the Company’s ongoing monitoring systems. We deliver training to help employees understand regulation, compliance, fraud awareness, corruption, and sanctions requirements.

Money Laundering Reporting Officer

The Change has appointed a Money Laundering Reporting Officer who is responsible for the Anti-Money Laundering and Counter Funding Of Terrorism Function and effective identification, management and control of ML and FT risk.

Cooperation with Government Bodies

The Company is committed to the fight against money laundering and the financing of terrorism. As such, the Company will cooperate with any request emanating from an authorized law enforcement authority.