AML / CTF Policy
Misoneism Limited T/A Elite Bitcoin Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy – Updated December 15th 2020
This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter the ‘AML/CTF Policy’) is designed to stipulate the commitment of MISONEISM LIMITED (“the company”, “we”, “us”, “our”) to detect, prevent and report attempts to use its financial services platform (the “Services”) to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, or to commit fraud.
Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals are known to specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions. Moreover, terrorist financing is the raising, moving, storing and using of financial resources for the purposes of terrorism.
Ethical behavior is an integral part of our business model. Therefore we do not tolerate any illegal or illicit activity from either our Customers or employees, and the company is committed to the highest standards for preventing money laundering, financial crime (including bribery and corruption), terrorism financing and other acts punishable by law.
This AML/CTF Policy outlines the principles, strategic objectives and requirements, including internal safeguards and customer due diligence duties, that underpin our commitment to combatting and preventing money laundering, financial crime, terrorism financing and other acts punishable by law.
1. Objectives of the AML/CTF Policy
1.1 As a relevant person under Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), we have an obligation to assist in the efforts to prevent the use of the financial system and economic space of the United Kingdom for money laundering and terrorist financing purposes.
1.2 The broad purpose of this AML/CTF policy is to ensure that we meet the obligations of MLRs and conform with the requirements of the Financial Conduct Authority (FCA) and other relevant law enforcement authorities.
2. Customer Verification Procedures
2.1 One of the international standards for preventing illegal activity is Customer due diligence. The company has established its own verification procedures within the standards of “Know Your Customer” frameworks.
2.2 Our identity verification procedure requires the Customer to provide us with reliable, independent-source documents, data or information.
2.3 We will take steps to confirm the authenticity of documents and information provided by Customers. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain Customers who match a higher risk profile or appear suspicious.
2.4 We reserve the right to review Customer’s proof of identity documents on an on-going basis, especially where identification information has changed, or activity appears suspicious / unusual for a particular Customer. We can decide which traits / activities are deemed suspicious at our sole discretion.
2.5 The company reserves the right to request up-to-date documents from its Customers, even if they have previously passed identity verification.
3. Monitoring of Transactions
3.1 Customers must complete the company’s identity verification process (who you are) before trading. After verification is completed, the Customer consents to transaction monitoring. We will continue to analyse the Customer’s transactional patterns (what they do).
3.2 We rely on data analysis as a risk-assessment and suspicious activity detection tools. These tools perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.
3.3 In connection with the AML/CFT Policy, The company will:
(a) monitor all transactions. We reserve the right to ensure that transactions of suspicious nature are reported to the National Crime Agency (NCA);
(b) request the Customer to provide any additional information and documents in case of suspicious transactions;
(c) suspend or terminate Customer’s Account when we have a reasonable suspicion that such Customer is engaged in illegal activity.
The above list is not exhaustive, and the Money Laundering Reporting Officer will monitor Customers’ transactions on a regular basis to define whether such transactions are to be reported and treated as suspicious.
4. International Sanctions Compliance Risk
4.1 The company must adhere to financial sanctions and embargoes against certain persons, entities and countries as published by the United Nations, the European Union, OFAC and UKHMT Office of Financial Sanctions Implementation.
4.2 The company must adhere to financial sanctions and embargoes against certain persons, entities and countries as published by the competent national authorities of their location.
4.3 The company must screen all Customers and beneficial owners against relevant sanctions lists before any transaction can be carried out or before any business relationship can be established. In cases where persons or entities involved in the transaction or business relationship are subject to sanctions as mentioned above, the transaction must not be
conducted, or the business relationship must not be established or continued.
4.4 The company must adhere to the applicable processing regulations or asset and funds freezing regulations.
4.5 We may decide at our sole discretion not to process transactions, provide services or otherwise facilitate transactions, even where permitted by applicable sanctions, laws and regulations.
5. Regulatory Compliance Risk
5.1 The company ensures that it adopts all regulatory, legal and compliance requirements and values in a proportionate way that satisfies the requirements of the regimes in a pragmatic, cost-effective and ethical manner. We maintain a zero tolerance for regulatory fines. Consequently, noncompliance to regulatory requirements shall immediately trigger mitigation/rectification actions.
6. Money Laundering Reporting Officer
6.1 The Money Laundering Reporting Officer is the person, duly authorized by the company, whose duty it is to ensure the effective implementation and enforcement of the Policy. The Money Laundering Reporting Officer is obliged to have relevant education and specific knowledge and expertise in AML/CTF fundamental and practical issues.
6.2 It is the Money Laundering Reporting Officer’s responsibility to supervise all aspects of implementing this Policy including, but not limited to:
collecting Customers’ identification information; establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under applicable laws and regulations; monitoring the transfer of assets and investigating any significant deviations from normal transfer activity; implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; and regularly updating risk assessment.
6.3 The Money Laundering Reporting Officer is entitled to interact with competent authorities involved in the prevention of all types of illegal activity.
7.1 All of our employees and officers receive ongoing broad-based AML/CTF training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.
8. Risk Assessment
8.1 In order to meet its obligations regarding Anti-Money Laundering and Counter-Terrorist Financing, the company completes an annual AML/CTF Risk Assessment. The aim of the AML/CTF Risk Assessment is to prevent criminals from using us to launder money by highlighting risks and assessing controls we have put in place. A risk-based approach is taken to identify Customers and monitor how they use our Services.
8.2 The Money Laundering Reporting Officer is responsible for managing financial crime risks and making improvements in financial crime risk management by identifying the general and specific money laundering risks that we are facing, determining how these risks are mitigated by our AML/CTF controls, and establishing the residual risk that remains for us.