Anti-Money Laundering and Know Your Customer Policy

The terms used in this Policy shall be interpreted in accordance with the definitions given in the Appendix to the Bitbon System Public Contract Terms and Definitions in the Bitbon System Social Network.

The Verifier is a person whose duty is to ensure the efficient implementation of and compliance with this Policy. It is the Verifier’s responsibility to supervise all aspects of this Policy, including:

• collecting the User’s personal data;
• establishing and updating internal policies and procedures for the completion, review, submission and storage of all reports and records required under the applicable laws and regulations;
• monitoring actions of the User and investigating any significant deviations from normal activity;
• implementing a record management system for appropriate storage and retrieval of documents, files, forms and logs;
• updating risk assessment regularly;
• providing law enforcement authorities with the necessary information as required under the applicable laws and regulations.

The Users are verified by establishing their identity, as well as by analyzing their transaction patterns. Therefore, the Operator relies on data analysis as a
risk-assessment and suspicious activity detection tool. The Operator performs a variety of compliance-related tasks, including collecting and organizing data,
record-keeping, investigation management and reporting.

In accordance with this Policy, the Operator shall monitor all actions and reserves the right to:

• interact with the law enforcement authorities involved in prevention of money laundering, terrorist financing and other illegal activities, as well as to report on suspicious actions to law enforcement authorities;
• request the User to provide any additional information or documents in the event of suspicious actions;
• fully or partially suspend or terminate the User’s Bitbon System Account[i] when the Operator has grounds according to the Appendix to the Bitbon System Public Contract Bitbon System Account.

The above list is not exhaustive, and the Operator shall monitor Users’ actions in order to define whether such actions are to be treated as suspicious and reported or not.

One of the international standards for preventing illegal activities is the User[i] due diligence (CDD — Customer Due Diligence). According to CDD, the Operator[i] establishes its own verification procedures within this Policy.

Identity Verification

• Taking anti-money laundering measures, the Verifier requires Users to provide appropriate documents that confirm their identity.
• The Verifier’s[i] identity verification procedure requires the User to provide the official, independent source documents or information (e.g., national ID, international passport, bank statement or utility bill). For the purposes of this Policy, the Verifier reserves the right to inquire the User’s personal data, as well as to take steps to confirm the authenticity of documents and information provided by Users. The Verifier shall take all legal measures to verify identification data. The Verifier reserves the right to collect information about the Users who have been determined to be risky or suspicious.
• The Verifier is not authorized and obliged to ascertain whether the document the User provides for identification is legal. However, in the event of evident inconsistency of the received information, the Verifier has the right to demand additional identification documents from the User. If the User refuses to provide the required information, when needed, or tries to mislead the Verifier, such a User may be denied in providing the services.
• The Verifier reserves the right to verify the User’s identity on an on-going basis, especially when the User’s personal data has been changed or his/her activities seemed to be suspicious (unusual for the particular User). In addition, the Verifier reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
• The User’s personal data is collected, disclosed and protected strictly in accordance with the Appendix to the Bitbon System Public Contract Privacy Policy.
• Once the User’s identity has been verified, the Verifier may relieve itself of potential legal liability in a situation where provided services and/or products are used by the User to conduct illegal activities.
• If the Verifier reveals suspicious activities of the User related to money laundering, terrorist financing, illegal drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, the information about such activity shall be reported to the relevant authorities.

In accordance with the international requirements, the Operator has applied a risk-based approach to combating money laundering and terrorist financing. In this way, the Operator is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks, which is one of its priorities.

In the case of the arising questions regarding this Policy, one should contact the Support Service with a request in accordance with this Policy.

Amendments and/or additions to this Policy may be made solely under the rules provided for the Appendix to the Bitbon System Public Contract Making Amendments and/or Additions to the Bitbon System Public Contract.

If there is any discrepancy between various versions (printed, electronic, etc.) of this Policy, its electronic version published on the official information resources of the Bitbon System[i] shall be deemed the official one.

This Policy is translated into other languages only for convenience of Users. In case of differences in understanding and/or interpretation of this Policy, the Russian version shall prevail.

Only the Operators are entitled to give an official explanation of this Policy.

In accordance with Provision 2 of the Bitbon System Public Contract, this Policy is an integral part of the Bitbon System Public Contract and comes into force after its publication on the official information resources of the Bitbon System.

In accordance with paragraph 3 of Provision 2 of the Bitbon System Public Contract, amendments and/or additions may be made to this Policy only if such amendments and/or additions do not contradict the Provisions of the Bitbon System Public Contract and Appendices, which are an integral part of the Bitbon System Public Contract. Amendments and/or additions made to this Policy shall be published on the official information resources of the Bitbon System and come into force in accordance with the Appendix to the Bitbon System Public Contract “Making Amendments and/or Additions to the Bitbon System Public Contract”.