Last updated: May 23, 2018
APPENDIX 2: AML/KYC PROCEDURES
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (hereinafter the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of BITKUB Online Company Limited (hereinafter “We”) being involved in any kind of illegal activity.
We are not subject to local AML or KYC legislation in Thailand; Nevertheless, We intend to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from our Users.
AML/KYC Policy covers the following matters:
- Verification procedures;
- Compliance Officer;
- Monitoring Transactions; and
- Risk Assessment.
1. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). We establish its own verification procedures within the standards of AML and KYC frameworks:
1.1. Identity verification
Our identity verification procedure requires users to provide us with accurate documents, data or information (e.g., national ID, international passport, bank statement, utilities bill). For such purposes, We reserve the right to collect users’ identification information for our AML/KYC Policy.
We will take steps to affirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used provided that We reserve right to investigate certain users who have been determined to be risky or suspicious.
We reserve the right to verify users’ identity in the on-going basis, especially when their identification information have been changed or their activity seemed to be suspicious according to our discretion (unusual for the particular User). In addition, We reserve right to request up-to-date documents from the Users, even though they have passed identity verification.
1.2. Card verification
The Users who are intended to use payment cards in connection with Our Services have to pass and/or complete card verification in accordance with instructions available on Our Site.
2. Chief Compliance Officer
The Chief Compliance Officer (“CCO”) is the person, duly authorised by us, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is his responsibility to supervise all aspects of our anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users’ identification information;
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
- Monitoring transactions and investigating any significant deviations from normal activities;
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- Regularly updating risk assessments; and
- Providing law enforcement with information as required under the applicable laws and regulations
3. The CCO is entitled to interact with law enforcement, which is involved in prevention of money laundering, terrorist financing and other illegal activities.
The Users are known not only by verifying their identity but, more importantly, by analysing their transactional patterns (what they do). Therefore, We rely on data analysis as a risk-assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
- Case and document management.
4. With regard to the AML/KYC Policy, We will monitor all transactions and it reserves the right to:
(a) Ensure that transactions of suspicious nature are reported to the proper law enforcement through the CCO;
(b) Request the User to provide any additional information and documents in case of suspicious transactions;
(c) Suspend or terminate User’s Account when We have reasonably suspicious that such User engaged in illegal activity.
The above list is not exhaustive and the CCO will monitor Users’ transactions on a daily basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
5. Risk Assessment
We, in line with the international requirements, have adopted a risk-based approach to money laundering and financing of terrorism. By adopting a risk-based approach, We are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.