Anti Money Laundering Policy (AML Policy)
Money laundering is the act of covering-up of illegal resources by converting them into cash or seemingly legitimate investments.
As Bitci Borsa Teknoloji A.Ş. (“Bitci”), we take the matter of providing the best customer service to our customers very seriously, including a strong emphasis on account security. In order to prevent money laundering with any means whatsoever, we strictly follow the AML (Anti-Money Laundering) Policy. Within this framework, the Anti-Money Laundering Policy (hereinafter to be referred to as the “AML Policy”) outlines the procedures and mechanisms established by Bitci to prevent money laundering.
The objective of the Anti-Money Laundering Policy is to minimize the risks by evaluating Bitci’s customers, transactions and services with a risk-based approach, to raise the level of awareness of and inform the employees about the prevention of money laundering and financing of terrorism. In addition, the policy is also aimed to inform customers that the Company carries out its activities in accordance with the applicable legislation, and in particular Law No. 5549 on the Prevention of Laundering Proceeds of Crime and Law No. 6415 on the Prevention of Financing of Terrorism.
Within the scope of this AML Policy, in order to prevent any prejudice to Bitci's activities, the customers for whom an AML policy is applicable refers to the natural person who is a member of the platform accessed at www.bitci.com.tr ("Platform") and who benefits from the services offered on the Platform and who accepts the matters set out in this AML Policy in return.
Bitci has issued its AML Policy in accordance with international legal norms and standards and taken numerous measures concerning its implementation such as verifying the identities of all customers to a reasonable extent, applying a risk-based approach to monitoring customer transactions, notifying the relevant institutions and organizations of any suspicious transactions carried out by the customers within the framework of the current legislation and recording these transactions, and establishing the necessary organization to coordinate the implementation and applicability of the AML Policy within Bitci.
Accordingly, Bitci implements the following policies:
- Not to enter into business relations with criminals and/or terrorists;
- Not to process any transactions arising from criminal and/or terrorist activities;
- Not to facilitate any transactions related to criminal and/or terrorist activities.
Risk assessment
In line with international requirements, Bitci has adopted a risk-based approach to money laundering and financing of terrorism. Therefore, measures to prevent money laundering and financing of terrorism are commensurate with identified risks and allow for the effective commitment of resources. Resources are used on a priority basis and the greatest risks are attached the greatest attention.
As Bitci adopts a risk-based approach in monitoring the financial activities of its customers, it is capable of performing risk analysis by using the following methods and monitoring the relevant customers within the framework of the information obtained as a result of the risk analysis with the purpose of preventing money laundering and financing of terrorism.
Customers and transactions in the high-risk group are as follows:
- In case the total amount of a single cryptocurrency transaction or multiple linked transactions is equal to or more than TL 100,000.00;
- In case the total amount of a single cryptocurrency exchange or multiple linked exchanges is equal to or more than TL 100,000.00;
- In cases when it is required to report suspicious transactions within the framework of current legislation;
- In the event that there is any doubt about the accuracy and adequacy of previously acquired identity information;
- In cases of complex transaction that have the potential to hide third party beneficiaries;
- In cases when the financial funds cannot be easily verified;
- Unusual transactions without an economic or apparent legitimate purpose.
Transaction Monitoring
Monitoring customer transactions and analyzing the obtained data is also an essential tool for risk assessment and the detection of suspicious transactions. In case of suspicion of money laundering, Bitci has the right to monitor all transactions (high-risk Customers and transactions, complex and unusual transactions, transactions with high-risk countries, Customer information and documents, written and mandatory information required to be retained regarding the trading and transfer of crypto assets, whether a transaction carried out by a Customer is in accordance with the information related to such transaction, etc.) and to do the following:
- Reporting suspicious transactions to the relevant law enforcement authorities;
- Requesting additional information and documentation from the Customer;
- Suspending or to terminating the Customer’s account;
The list provided above is not an exhaustive one and the AML Policy Compliance Supervisor monitors the customers’ transactions on a daily basis to establish whether to report the customers and to consider their actions as suspicious.
Know Your Customer Policy
Detailed information about the Know Your Customer Policy is available via the link bitci.com.tr/kyc.
Verification Procedure
Bitci will establish its own procedures to establish anti-money laundering standards and compliance with its Know Your Customer (KYC) Policy.
Bitci customers have to complete a verification procedure (by submitting a government-approved ID: passport or identity card). For the purposes of the AML Policy, Bitci reserves the right to collect the identity information of its customers. This information will be processed and securely stored in accordance with Bitci’s Privacy Notice.
Bitci may request a second customer ID document: (a bank receipt or recent electricity/water bill not older than 3 (three) months that contains the customer’s full name and real address).
After confirming the accuracy of the documentation and information submitted by the customers, Bitci reserves the right to request additional information about any customers who are designated as dangerous or suspicious.
If the identity information of the customer has been changed or his/her activities have been found suspicious, Bitci reserves the right to request updated documentation from the customers even if their identity has been verified previously.
Reporting
Within the framework of services provided by Bitci, in case of any suspicion regarding money laundering and financing of terrorism, any transactions that are designated as suspicious as a result of necessary investigations will be reported to local or international authorities in accordance with the current legislation and regardless of the amount involved. All kinds of legal, administrative and criminal sanctions will be applicable to real persons who carried out the suspicious transaction and their legal representatives, the managers and personnel who fail to comply with the obligation to report suspicious transactions.
Anti-Money Laundering Supervisor
Anti-Money Laundering Supervisor is a Bitci employee who is responsible for ensuring compliance with the AML Policy. Anti-Money Laundering Supervisor is charged with the following:
- Collecting the customers’ identity information,
- Establishing and updating internal policies and procedures for generating, reviewing, submitting and retaining all necessary reports.
- Monitoring and analyzing significant deviations due to the customers’ unusual activities,
- Implementing a record management system for recording and retrieving documents, files, forms and daily log-ins,
- Updating the risk assessments on a regular basis.
Training, Updating and Internal Audit
With its personnel policy and procedures issued in compliance with the current legislation, Bitci is fulfilling all of its obligations in terms of training. Within this framework, the Company is providing training to its personnel, especially on Anti-Money Laundering Procedures, and ensures that this information is kept up-to-date.
Bitci is periodically auditing whether its activities related to the "Law against Money Laundering and Financing of Terrorism” as well as regulations and communiqués are in compliance with the applicable legislation, Company policies and procedures.