Bitcoin Store | Anti-Money Laundering (AML) Program and Know Your Customer (KYC) Procedure

Bitcoin Store promotes the highest level of compliance with the Anti-Money Laundering and Terrorist Financing Act and demands from the management board and its employees to follow the mentioned standards.

Money laundering is the process of conversion of funds derived from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments which appear legitimate for the purpose of concealing the actual origins of funds.

The process of money laundering can be divided in three stages:

Placement

At this stage funds are converted into financial instruments such as checks, bank accounts and money transfers or can be used for purchase of goods of high value, which can be sold. Funds can also be physically stored in banks and non-bank institutions (for instance exchange offices). To avoid suspicion, money laundering can simultaneously perform several deposits, instead of depositing the whole sum at once.

Layering

Funds are transferred, relocated to other accounts or other financial instruments, with the purpose of concealing its origins so it is unclear who performed multiple financial transactions. Relocation of funds and changing of its form makes it difficult to track the money being laundered.

Integration

Funds are recirculated as legitimate, and different kinds of goods and services are bought with them.

Anti-Money Laundering Policy

Bitcoin Store, like most other companies providing services on the financial market, complies with the principles of countering money laundering and actively prevents all actions which are aimed at or facilitate the process of illegal funds legalization. AML Policy means to prevent the usage of Bitcoin Store services by crime with the aim of money laundering, terrorist financing or other criminal activities.

For that purpose the company introduced strict policy of detection and prevention of all suspicious activities and warnings of competent bodies of such activities. Bitcoin Store does not have the obligation to notify the clients that bodies competent for law enforcement have been informed on their activities. A complex electronic system has been introduced to identify clients and keep detailed history on all operations.

Bitcoin Store retains the right to suspend the service to the client if, according to the opinion of the employees, there is any doubt whatsoever that the funds are acquired illegally.

Procedure

Bitcoin Store will determine whether it transacts with a natural or a legal person. Bitcoin Store also exercises all necessary measures in accordance with applicable legal acts and regulations issued by monetary authorities. Bitcoin Store exercises AML procedures by following these rules:

  • client identity verification and due diligence;
  • monitoring client's activities;
  • keepig records.

Determination - client identity verification and due diligence

Every client whose transaction exceeds EUR 1,000 (7,500 Croatian Kuna) has to complete the identification process. Before initiating cooperation with such client, Bitcoin Store will ensure satisfactory proof of identity (identity card or passport).

If the documents are written in non-Latin characters, it is necessary to submit a certified translation of the document in English or Croatian.

Bitcoin Store also applies intensified control of clients who are non-residents of the Republic of Croatia, especially of clients from countries with inadequate AML standards or who can represent high risk of crime and corruption.

Natural persons

During the identification process, each client provides personal data: name and surname, date of birth, nationality, address, personal identification number (OIB), title, number and issuer of the identification document.

Data are stored in accordance with the General Data Protection Regulation (GDPR).

Corporate clients

If the client is a commercial company, the following is to be submitted: excerpt from the Commercial Registry, names and addresses of the directors and persons authorized to represent the company. Authorized person provides personal data: name and surname, date of birth, nationality, address, personal identification number (OIB), title, number and issuer of the identification document.

If the company is owned by another company, it is necessary to determine the beneficial owner, i.e. repeat this procedure also for the parent company.

Data are stored in accordance with the General Data Protection Regulation (GDPR).

Monitoring client activities

In addition to collecting client data, Bitcoin Store continues to monitor each client's activity in order to recognize and prevent suspicious transactions. Suspicious transaction is determined as a transaction which is not in conformity with legitimate business operations or the usual transaction history of the client, which is known due to the monitoring of client's activities. Bitcoin Store has implemented a monitoring system for mentioned transactions (automated, as well as manual) in order to prevent the usage of company services by crime.

Deposit and withdrawal conditions

All deposits and withdrawals of clients' funds must comply with the following conditions: when transferring funds, name and surname stated during the registration has to correspond to the name of the account owner.

In any case, no deposit or withdrawal is permitted to third persons.

Tomislav Vajic
director
Last alteration: 8/23/2018