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AML POLICY

BITGLIDE ANTI-MONEY LAUNDERING AND KNOW-YOUR-CUSTOMER POLICY

INTRODUCTION

BITGLIDE Anti-Money Laundering and Know-Your-Customer Policy (hereinafter the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of BITGLIDE being involved in any kind of illegal activity.
BITGLIDE, as an obliged institution, is committed to preventing money laundering and terrorist financing, and to ensuring compliance with all applicable anti-money laundering/counter financing of terrorism (“AML/CFT”) laws and regulations. To that extent, BITGLIDE has established this AML/KYC Policy.
Legal regulations require BITGLIDE to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, and to take action in case of any form of suspicious activity from its Clients.
This AML/KYC Policy applies to all BITGLIDE Clients. By creating an account on our Website and/or using our Services, the Client accepts this AML/KYC Policy and agrees to abide by its AML and KYC procedures.
PLEASE READ THIS AML/KYC POLICY CAREFULLY.
This AML/KYC Policy covers the following matters:
  1. Legal Information about BITGLIDE
  2. AML Measures
  3. KYC Procedures and Due Diligence
  4. Compliance Officer
  5. Risk Assessment
  6. Termination of Services
  7. Confidentiality
  8. Contact Information

1. LEGAL INFORMATION

The website https://bitglide.cc/ ("Website") and its Services are operated and provided by BITGLIDE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (BitGlide sp. z o.o.), registered under the laws of Poland with the National Court registration number 0001031417, registered address at Ostrobramska 101, 04-041 Warsaw, Poland (“BITGLIDE”, "we," "us," or "our").

2. AML MEASURES

BITGLIDE AML policy includes the following measures:
  1. Customer Identification and Verification: we have procedures in place to verify the identity of our customers, including the collection and verification of personal information such as name, address, and government-issued ID.
  2. Risk Assessment: we conduct ongoing risk assessments to identify and assess any potential money laundering or terrorist financing risks associated with customers, services, and geographic locations.
  3. Suspicious Activity Reporting: we have procedures in place for the reporting of suspicious activity to the appropriate authorities.
  4. Record Keeping: we maintain accurate and complete records of all transactions and customer identification information in accordance with applicable laws and regulations.
  5. Employee Training: All employees are trained on our AML policies and procedures and applicable laws and regulations.
  6. Reporting: we have an internal system for reporting to regulatory authorities as required by law.
  7. Compliance Officer: we have a designated compliance officer responsible for monitoring compliance with AML regulations and implementing the Platform's AML policies and procedures.

3. KNOW YOUR CUSTOMER (KYC) PROCEDURES AND DUE DILIGENCE

Know Your Customer (KYC) procedures allow BITGLIDE to verify the identity of every Client and assess any potential risks for illegal activities such as money laundering or financing terrorism. This is done by collecting and verifying personal information, such as a government-issued ID and proof of address. BITGLIDE also monitors transactions for unusual or suspicious activity.
3.1. Identity verification procedure. BITGLIDE has implemented procedures to verify the identity of our Clients prior to conducting any business transactions. These procedures include, but are not limited to, the collection and verification of the following information and documentation:
  1. Full name
  2. Date of birth
  3. Nationality
  4. Telephone number and email
  5. Address
  6. Government-issued ID, such as a passport or national ID card
  7. Proof of address, such as a utility bill or bank statement
Additional documentation may be required for high-risk Clients.
3.2. Sanctions and PEP lists screening. BITGLIDE has implemented procedures to screen Clients against government-sanctioned lists and Politically Exposed Persons (PEP) lists. These procedures include, but are not limited to, the following:
  1. Initial screening at the time of account opening or onboarding of a new client.
  2. Periodic re-screening of existing clients in accordance with regulatory requirements and internal policies.
  3. Utilizing a reliable and up-to-date screening database or service provider.
3.3. High-risk countries or regions. BITGLIDE has implemented additional due diligence procedures for individuals or entities from high-risk countries or regions, as determined by our internal policies or regulatory requirements.
Please note that BITGLIDE refuses to conduct business with Clients from the following territories: Afghanistan, Albania, Algeria, Angola, Argentina, Bahrain, Bangladesh, Barbados, Belarus, Benin, Bhutan, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, British Antarctic Territory, Burkina Faso, Burundi, Cambodia, Cameroon, Cabo Verde (Cape Verde), Central African Republic, Chad, China, Colombia, Comoros, Congo DR, Costa Rica, Cote D'Ivoire, Crimea Region, Cuba, Djibouti, Dominican Republic, Ecuador, Egypt, El Salvador, Equatorial Guinea, Eritrea, Eswatini (Swaziland), Ethiopia, Fiji, Gabon, Gaza Strip, Ghana, Guam, Guatemala, Guinea, Guinea Bissau, Guyana, Haiti, Honduras, Iran, Iraq, Jamaica, Jordan, Kenya, Kiribati, Kosovo, Kuwait, Laos, Lebanon, Lesotho, Liberia, Libya, Macedonia FYR, Madagascar, Malawi, Maldives, Mali, Mauritania, Mexico, Morocco, Mozambique, Myanmar (Burma), Namibia, Nepal, Nicaragua, Niger, Nigeria, North Korea, Northern Cyprus, Oman, Pakistan, Palau, Panama, Paraguay, Peru, Puerto Rico, Qatar, Russian Federation, Rwanda, Samoa, Sao Tome and Principe, Saudi Arabia, Senegal, Sierra Leone, Somalia, South Sudan, Sri Lanka, St. Lucia, Sudan, Suriname, Syria, Tajikistan, Tanzania, Timor Leste, Togo, Trinidad & Tobago, Tunisia, Turkey, Tuvalu, Uganda, USA, Vanuatu, Vatican City, Venezuela, Virgin Islands (US), West Bank, Yemen, Zambia, Zimbabwe.
3.4. Monitoring Transactions. The Clients are known not only by verifying their identity in order to know who they are but, more importantly, by analysing their transactional patterns that provide an indication of the actions of Clients. Hence, BITGLIDE has also implemented procedures to verify and monitor the transactions of its Clients in order to detect and prevent fraudulent or illegal activities. These procedures include, but are not limited to, the following:
  1. Verifying the identity of the cardholder or account holder prior to processing transactions.
  2. Utilizing measures to authenticate transactions, such as CVV, OTP, and biometric verification.
  3. Monitoring transactions for unusual or suspicious activity, such as large or frequent transactions.
  4. Implementing transaction limits and flagging or declining transactions that exceed these limits.
  5. Retaining transaction records in accordance with regulatory requirements and internal policies.
3.5. Due Diligence. BITGLIDE may conduct different levels of due diligence on a Client or transaction in order to comply with AML/CFT regulations: simplified due diligence (SDD) and enhanced due diligence (EDD). The decision of whether to apply SDD or EDD depends on the risk factors, such as the country of origin, PEP status, and the nature of the transaction.
3.5.1. Simplified Due Diligence. SDD is applied to lower-risk Clients or transactions, and generally involves the collection and verification of basic customer information, such as a government-issued ID and proof of address. It usually requires less documentation, less in-depth analysis, and less ongoing monitoring of the Client’s transaction.
3.5.2. Enhanced Due Diligence. EDD is applied to higher-risk Clients or transactions, and generally involves a more in-depth analysis of Client's background. It often requires additional documentation, such as source of funds, as well as ongoing monitoring of the Customer's transaction. We may also apply EDD to PEP or to transactions that are related to certain countries or jurisdictions that are considered higher risk.

4. COMPLIANCE OFFICER

BITGLIDE has appointed the Compliance Officer who is responsible for ensuring that the company's AML policies and procedures are implemented and followed effectively.
The Compliance Officer oversees the BITGLIDE's compliance with AML laws and regulations; develops, implements and updates the BITGLIDE's AML policies and procedures; provides training and guidance to employees on AML compliance; regularly assesses and reports on the BITGLIDE's AML compliance program; investigates and reports suspicious activities to the appropriate authorities.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

5. RISK ASSESSMENT

BITGLIDE has adopted a risk-based approach to combating money laundering and terrorist financing in adherence to the international requirements. Under the risk-based approach BITGLIDE is able to identify, assess, and understand the emerging money laundering/terrorist financing risks and ensure that measures to prevent or mitigate money laundering/terrorist financing risks are commensurate with the risks identified.
BITGLIDE risk assessment will take into account all of the risk factors that BITGLIDE as well as its competent authorities consider relevant, including the following:
  • the types of services, products, or transactions involved;
  • customer risk;
  • geographical factors;
  • type(s) of virtual currency exchanged,
among other factors.
By assessing these individual factors, BITGLIDE can allocate a risk rating to a transaction or client relationship.
There are some general key risk drivers that may be considered by BITGLIDE in each risk assessment:
  • Clients seeking undue anonymity or secrecy and not willingly revealing their identity.
  • Clients acting through a third party or Clients introduced to us by a third party, as we do not know the due diligence that has taken place.
  • Clients involved with cash-based businesses.
  • Clients from abroad, especially from countries with low regulatory standards, high corruption or sanctions.
  • Clients from outside the usual customer base.
  • Clients with, or operating for an individual with, high net worth.
  • Clients with a criminal history.
  • Politically exposed clients.
  • Large transactions.
  • One off transactions.
If the risk assessment conducted by BITGLIDE finds any of these key risk drivers or has any concerns, then the BITGLIDE’s anti-money laundering check procedures will be followed.

6. TERMINATION OF SERVICES

BITGLIDE has the right to terminate its business relationship with and cease to provide its Services to any Client who is found to be in violation of the BITGLIDE's AML/KYC policy or any applicable laws and regulations. This includes, but is not limited to, the following circumstances:
  1. Failure to comply with the company's KYC procedures and provide the required documentation.
  2. Providing false or misleading information during the KYC process.
  3. Engaging in suspicious or illegal activities, such as money laundering or financing of terrorism.
  4. Refusing to cooperate with the company's AML investigations or reporting requirements.

7. CONFIDENTIALITY

BITGLIDE maintains the confidentiality of all Client information and records, as well as information related to suspicious activities, in accordance with our Privacy Policy and applicable laws and regulations.

8. CONTACT INFORMATION

For more information on this AML/KYC Policy or our AML/KYC procedures, please contact us via email at info@bitglide.cc.

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BITGLIDE sp.z.o.o., Reg.Nr. 0001006127, Address at CHODAKOWSKA 53/57, office 22A, Warsaw, 03-816, Poland.
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