Anti-Money Laundering Programme

Principles

• Anti-Money Laundering is at the core of Bittylicious. This includes Bittylicious having adequate systems and control in place to mitigate the risk of Bittylicious being used to facilitate the laundering of the proceeds of crime.
• Senior management is responsible for the oversight of compliance with relevant legislation, regulations, rules and industry guidance.
• The verification requirements and limits are regularly updated after following a Risk Based Approach towards assessing and managing the fraud, money laundering and terrorist financing risks to the company.
• Risk vectors and ML techniques change regularly, so these requirements and limits are regularly updated.
• Customer activity is monitored in an on-going basis, including detection of accounts being used in a manner inconsistent with previous usage.
• Suspicious activity is reported internally and onwards to the relevant law enforcement authorities, e.g. by raising SARS if appropriate.
• Historical information is maintained for appropriate amounts of time in order to identify trends.
• All relevant employees are trained to understand these requirements.

Limits

• Customers that we do not 'know' are only entitled to buy small amounts of cryptocurrency. These are below any thresholds that money launderers would consider useful.
• In order to buy a slightly increased amount of cryptocurrency, customers are required to register (i.e. confirm their email address) and also confirm a mobile phone number.
• In order to increase that limit further, more extensive ID checks are performed in the form of:
  • ID verification.
  • Proof of address verification.
  • Bank account verification.
• The limit can be raised further, but in all instances, we open up dialogue with you to understand the reasoning for wanting cryptocurrency, and cross check this where possible.

Enhanced due diligence is additionally performed on any customers that present a higher risk, for example, Politically Exposed Persons (PEPs).

Anti-Abuse

We take active steps to stop users from abusing the limits we set. Amongst other things, we:

• Set strict time limits between starting and completing trades.
• Restrict the number and amount of trades per IP address and IP block.
• Cross-reference information received from banks concerning account names.

Regulations

Systems, as described above, have been implemented that meet the required UK AML legislation required of registered entities. This is above and beyond what is required, but the interests of Bittylicious and these regulations are aligned.

UK Legislation enacted to combat money laundering includes:

• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (SI 2017 No. 692), as amended in 2019.
• The Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2015).
• The Terrorism Act 2000, as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007.
• The Criminal Finances Act 2017

Bittylicious also follows AML guidance provided by UK and international organisations, including (but not restricted to):

• the Joint Money Laundering Steering Group (JMLSG)
• the Financial Conduct Authority (FCA, UK)
• HM Treasury(UK)
• the Financial Action Task Force (FATF)