Anti-money laundering policy (AML & KYC)

AML / KYC Policy

Introduction

BIT2ME Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML / KYC Policy") is designated to prevent and mitigate possible risks of BIT2ME being involved in any kind of illegal activity.

Both international and local regulations require BIT2ME 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 its Users.

The AML/KYC policy covers the following matters:

• Verification procedures.
• Compliance officer
• Transaction tracking.
• 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, independent source documents, data or information (eg, national ID, international passport, bank statement, utility bill). For such purposes BIT2ME reserves the right to collect User's identification information for the AML/KYC Policy purposes.

BIT2ME will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used 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 can absolve itself of any potential 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 enforcement of the AML/KYC Policy. It is the Compliance Officer's responsibility to supervise all aspects of BIT2ME's anti-money laundering and counter-terrorist financing, among others:

1. Collecting user's identification information
2. 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
3. Monitoring transactions and investigating any significant deviation from normal activity
4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs
5. Regularly update the risk assessment.
6. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

3. Transaction monitoring

The 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 capturing data, filtering, record-keeping, investigation management, and reporting. System 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 suspicious nature are reported to the proper law enforcement 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 the transactions of the Users on a day-to-day basis to determine 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.