Anti-money laundering policy (AML & KYC)

PBC/KYC Policy

Introduction

BIT2ME's anti-money laundering and know your customer policy (hereinafter, the "PBC/KYC Policy") is designed to prevent and mitigate the potential risks of BIT2ME being involved in any type of illegal activity.

Both international regulations and the localizations that BIT2ME implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption and bribery, and take action in case of any form of suspicious activity from its users

The AML/KYC policy covers the following matters:

• Verification procedures.
• Compliance Officer
• Transaction monitoring.
• Risk assessment.

1. Verification Procedures

One of the international standards for preventing illegal activity is Customer Due Diligence ("CDD"). According to CDD, BIT2ME establishes its own verification procedures within the standards of the anti-money laundering frameworks and "Know Your Customer".

1.1. Identity Verification

BIT2ME's identity verification procedure requires the User to provide BIT2ME with reliable and independent documents, data, or information (for example, national identification, international passport, bank statement, utility bill). For such purposes, BIT2ME reserves the right to collect User identification information for the purposes of the AML/KYC Policy.

BIT2ME will take steps to confirm the authenticity of the documents and information provided by the Users. All legal methods will be used to verify the identification information and BIT2ME reserves the right to investigate certain Users who have been determined to be risky or suspicious.

BIT2ME reserves the right to continuously verify the User's identity, especially when their identification data has changed or their activity appears suspicious (unusual for the particular User). In addition, BIT2ME reserves the right to request updated documents from Users, even if they have passed identity verification in the past.

User identification information will be collected, stored, shared, and strictly protected in accordance with BIT2ME Privacy Policy and related regulations.

Once the User's identity has been verified, BIT2ME may withdraw from possible legal liability in a situation where its Services are used to carry out illegal activities.

1.2. Card Verification

Users who are intended to use payment cards in connection with BIT2ME Services must approve the card verification in accordance with the instructions available on the BIT2ME Site.

2. Compliance Officer

The Compliance Officer is the person, duly authorized by BIT2ME, whose duty is to ensure the effective implementation and compliance with the Anti-Money Laundering and KYC Policy. It is the responsibility of the Compliance Officer to oversee all aspects of BIT2ME's anti-money laundering and counter-terrorism financing, including, among others:

1. Collecting users' identification information
2. Establishment and updating of internal policies and procedures for the completion, review, submission, and retention of all reports and records required by applicable laws and regulations.
3. Monitoring transactions and investigating any significant deviation from normal activity
4. Implementation of a record management system for the proper storage and retrieval of documents, files, forms, and records.
5. Regularly updating the risk assessment
6. Providing law enforcement with the information required under applicable laws and regulations.

The Compliance Officer has the right to interact with law enforcement agencies, which are involved in the prevention of money laundering, terrorist financing, and other illegal activities.

3. Transaction Monitoring

Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, BIT2ME relies on data analysis as a risk assessment and suspicion detection tool. BIT2ME performs a variety of compliance-related tasks, including data capture, filtering, record-keeping, investigation management, and reporting. The system's functionalities include:

1. Daily verification of users against recognized "blacklists" (e.g., OFAC), aggregating transfers by multiple data points, placing users on watch lists and service denial, opening cases for investigation where necessary, sending internal communications, and completing legal reports, if applicable;
2. Case and document management.

With respect to the AML/KYC Policy, BIT2ME will monitor all transactions and reserves the right to:

• Ensure that transactions of a suspicious nature are reported to the appropriate police through the Compliance Officer.
• Request the User to provide additional information and documents in case of suspicious transactions.
• Suspend or cancel the user's account when BIT2ME reasonably suspects that such user engaged in illegal activities.

The above list is not exhaustive and the Compliance Officer will monitor Users' transactions on a day-to-day basis to define whether such transactions should be reported and treated as suspicious or whether they should be treated in good faith.

4. Risk Assessment

BIT2ME, in line with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, BIT2ME can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportional to the identified risks. This will allow resources to be allocated in the most efficient manner. The principle is that resources should be directed according to priorities so that the greatest risks receive the most attention.