AML / KYC Policy

Misoneism Limited T/A Elite Bitcoin Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy – Updated June 2020

  1. Money laundering is defined as the process of concealing the origins of money obtained through the proceeds of crime, by passing it through the financial system, for example by using a complex sequence of banking transfers or commercial transactions. The intended outcome of this process is to return “clean” money to the launderer that makes it appear as though the funds have come from a legitimate source (Proceeds of Crime Act 2002).
  2. Misoneism Limited, in accordance with the FATF definition, are classified as a financial institution as we accept deposits and other repayable funds from the public, issue and manage means of payment via electronic money, trade in transferrable securities, safekeeping and administration of cash or liquid securities on behalf of other persons and are involved in money and currency changing, for or on the behalf of our customers.
  1. Misoneism Limited is committed to ensuring the safety of its clients and compliance with the relevant legal requirements of the United Kingdom. In furtherance of this Misoneism Limited has implemented a Know Your Customer (KYC) policy which requires customer identification to be acquired in advance of depositing funds in order to combat money laundering and terrorist financing. By implementing this procedure and obtaining identification from 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 and identify where there is a requirement for enhanced due diligence.
  2. While Misoneism Limited’s operations aren’t currently regulated, we comply with the amended Money Laundering Regulations (MLR) set out by the Financial Conduct Authority (FCA) in its Cryptoassets: AML / CTF regime (2019). 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

  1. Misoneism Limited provides two approaches that customers may use 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 identification and associated relevant data:

KYC Company Identification

  1. In order for limited companies trading accounts to be verified we require further documentation to be supplied:
    • We will require customer identification in order to be in compliance with the FCA and FATF guidance where a company is used as a legal entity to either deposit cash at Point of Sale machines or execute online trades. In order to authenticate a company’s identity and subsequent transactions, the following documentation will be required:
      • Significant persons for the business that intends to execute trades;
      • A copy of the company’s 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

  1. Transactions and the information provided by our customers are analysed to look for suspicious or unusual behaviour. Selected transactions are evaluated to see if they cause significant AML / CTF risks. Customer trading may be ceased and / or clarified with the user. Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users.
  1. Any concerning or suspicious activity where we suspect that a person is attempting to, or intending to engage in money laundering will be submitted along with any and all evidence, as a Suspicious Activity Report, to the National Crime Agency (NCA) in accordance with the Proceeds of Crime Act 2002.

Additional verification

  1. In certain circumstances it may be necessary for customers to supply additional information to obtain verification. Circumstances in which additional verification will be required are when trade volume grows, or where a certain activity has been flagged on our systems. Requests for additional verification may be, but are not limited to:

  1. Inability to provide the additional verification will see the customers trading privileges revoked. In the event that a customer finds their trading privileges revoked and account frozen, they may release this account upon supplying the additional verification requested.

Disclaimer Acceptance

When operating one of our Point of Sale machines you are required to electronically accept that:

  1. You are over the age of 18;
  2. You are using the machine of your own free will;
  3. There is no third party involved in the transaction(s);
  4. The transaction is for legal purposes only;
  5. Is to, or from an address you own and control.

Sanctions and Screening