Effective date: May 09, 2018
Our AML program is designed to prevent the Bitcoin ATM from being used to facilitate money laundering and the financing of terrorist activities.
Our AML program incorporates policies, procedures, and internal controls designed to prevent and detect money laundering.
BCB ATM has a designated a compliance officer. Who is responsible for and tasked with day-to-day compliance.
Our AML program is available for ongoing, targeted compliance training.
Our AML program is subjected to an independent audit at least annually.
BCB ATM will Report and store certain customer and transaction records, as required.
BCB ATM will use the CDD process to collect pertinent information of the customer’s profile and evaluated for any potential money laundering or terrorist financing red flags.
BCB ATM will independently verify the information collected. These are legal documents that are issued by the government or an independent reputable agency.
Our compliance officer will then perform a check on a name-screening database or an internal blacklist to determine if a customer poses a risk to the financial institution.
BCB ATM will evaluate the customer on its risk it presents and proposes to the company on the decision of establishing business relationship with the customer. Decisions may involve understanding the circumstances of the clients.
If client has be evaluated to be at a heightened risk to the company. BCB ATM will begin the process of conducting ECDD obtain senior management approval before establishing a relationship, and take reasonable measures to establish the source of wealth and the source of funds. Examples of higher risk customers/transactions include but not limited to:
Politically Exposed Person (PEP)
Customer who are positively identified to have adverse profiles on watchlists
Non-face to face account opening
Customers located in high-risk location
Record keeping helps BCB ATM understands the company over the entire relationship with the customer. Record keeping helps the company deal with its reporting obligation in submitting documents to the local financial intelligence unit for suspicions on money laundering or terrorist financing.
Any activity determined suspicious by BCB ATM, will resort in the customer being blocked and will no longer be permitted to engage in any transactions via BCB ATM Bitcoin ATM’S. Therefore, an SAR will be filed and reported to the relevant authoritative department.