AML / KYC Policy
Misoneism Limited T/A Elite Bitcoin Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy
Money laundering is defined as the process of concealing the origins of money obtained through the proceeds of crime, by passing it through a complex sequence of banking transfers or commercial transactions. The intended outcome of this process is to return clean money to the launderer in an obscure and indirect way.
In regard for the safety of its clients and the legal requirements of the United Kingdom. Misoneism Limited has implemented a Know Your Customer (KYC) policy to acquire customer identification to combat money-laundering and terrorist financing. By obtaining identification of our users, we are able to monitor their transactions and conduct a Risk Based Approach (RBA) to assess whether they are suitable to continue to execute trades.
While Misoneism Limited isn’t currently regulated, it complies with the amended Money Laundering Regulations (MLR) set out by the Financial Conduct Authority (FCA) in its Cryptoassets: AML / CTF regime. As a business conducting cryptoasset activity prior to 10th January 2020 we intend to be registered and under the supervisory compliance of the FCA by its 10th January 2021 deadline.
Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users.
KYC Customer Identification:
Misoneism Limited applies two approaches for customers to conduct trades. The first is by using one of our Point of Sale machines, located within the South Wales region. The second is through online trading platforms. We will set out the ways in which we obtain customer data:
- Customers conducting Point Of Sale trades of over £250 must verify their mobile number through an SMS code text to their device. The mobile number becomes their account identifier.
- Customers conducting Point Of Sale trades of over £500 must verify their identity by scanning an image of their Passport or Driver’s License.
- The RBA is applied to verified individuals. Limits and suspensions can be applied in the case of suspicious activity and the customer can be prompted to provide additional information such as proof of address, or a selfie taken at the Point Of Sale to continue trading activity.
- When using trading platforms, the trading platforms themselves have already conducted their KYC due diligence. The company is then able to refine their listings to only be available for fully verified individuals. Additionally for trades over £1000 the company will require a copy of the customers ID.
- Larger, direct or accumulated online trades we will require at least two of the following; copy of the customers ID; proof of address dated within the last 3 months; selfie photo, holding the ID or a unique written note.
KYC Company Identification
In the case of limited companies we require further documents:
- We will require the former (customer identification) of a significant persons for the business that intends to execute trades; a copy of the companies incorporation document; a utility bill dated within the last 3 months with the company’s name and registered address; a copy of the shareholder certificate showing the individual as a significant person.
Risk Based Approach monitoring and reporting
Transactions are analysed to look for suspicious and unusual behaviours. Selected transactions are evaluated to see if they cause significant AML / CTF risks. Customer trading may be ceased and / or clarified with the user.
Any concerning suspicious activity where we suspect that a person is engaged in, or attempting, money laundering will be submitted as a Suspicious Activity Report to the National Crime Agency (NCA) in accordance to The Proceeds of Crime Act 2002.
It may be necessary to request additional verification. Such as when trade volume grows or with suspicious activity as noted above. Requests for additional verification may be, but are not limited to:
Proof of address dated within the last 3 months; selfie photo holding your ID, or a unique written note; screening for a Politically Exposed Persons (PEPs); Proof of Source of Funds.
Inability to provide the additional verification could see the customers trading privileges revoked.
When operating one of our Point Of Sale machines you are required to electronically accept that:
- You are using the machine of your own free will
- There is no third party involved in the transaction
- The transaction is for legal purposes
- Is to, or from an address you own and control.
Sanctions and Screening
Misoneism Limited only operates and conducts business within the United Kingdom jurisdiction. We are prohibited from transacting with individuals and businesses that are on the HM Treasury Sanctions List and will screen customers against the Office of Financial Sanctions Implementation (OFSI).