AML/CFT Policy

The Anti-Money Laundering, Countering Financing of Terrorism and Know Your Customer Policy (hereinafter - the "AML/CFT Policy") of YBITAZ is designated to prevent and mitigate possible risks of YBITAZ being involved in any kind of illegal activity.

Arbitration Rules

Any attempts to arbitrage coins without acquiring status are stopped by freezing withdrawals until status is acquired.

Money laundering also means participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the activities referred to above.

Terrorist financing is defined as the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism

Both international and local laws and regulations require YBITAZ to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.

AML/CFT Policy covers the following matters

Internal Controls

We have designed a structured system of internal controls in order to comply with applicable Anti-Money Laundering, Countering Financing of Terrorism (hereinafter - the "AML/CFT") laws and regulations, including, but not limited to:

Compliance Officer

The Compliance Officer is the person, duly authorized by YBITAZ, whose duty is to develop and enforce the effective implementation of the AML/CFT. The Compliance Officer is required to report any violations of the AML/CFT procedures and is responsible for collecting and filing SARs.

It is the Compliance Officer’s responsibility to supervise all aspects of YBITAZ’s anti-money laundering and counter-terrorist financing measures, including but not limited to:

The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.

Training

All employees receive a full AML/CFT training, along with a job‐specific guidance. Training is conducted at least once every twelve (12) months to ensure that trainees are informed and act in compliance with all applicable laws and regulations. Employees pass additional training if necessary (if new law or regulation is adopted, if required by law, etc.) New employees pass relevant training before commencing to work. Training program is updated regularly to reflect current laws and regulations.

Monitoring, risk assessment and risk-based approach

YBITAZ carries out customer’s transactions monitoring, risk‐assessment and suspicious activity detection. For that purpose it uses specially developed system, including using a high-performance tools.

YBITAZ uses risk-based approach to combating/preventing money laundry and/or financing terrorism.

To assist in determining the level of AML/CFT due diligence to be exercised with regard to the customer, a compliance risk profile is calculated first of all on entry into relations (Low, Medium, High), and is then recalculated routinely.

AML/CFT compliance ensures that an ongoing transaction monitoring is conducted to detect transactions which are unusual or suspicious compared to the customer profile.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty.

If a transaction is inconsistent with a customer’s known personal usual activities or personal habits, this transaction may be considered suspicious. Data and transaction monitoring tools are used to identify unusual/uncommon patterns of customer’s activity. After review and investigation, it is Compliance Officer’s decision whether to file a SAR or not.

Once a SAR is filed with a relevant agency, a copy of filing documentation is maintained. SAR filing is confidential and only the YBITAZ’s employees involved in the investigation and reporting process will be aware of its existence.

All records are retained for no less than (5) years and are available upon official request by an authorized examiner, regulator, or law enforcement agency.

Any YBITAZ staff member must inform the Compliance Officer of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

AML audit

The Compliance Officer is responsible for conducting AML/CFT audit at least annually. Other audit demands are set in internal policies and procedures.

Preservation of data

We retain the originals or copies of the documents, which serve as the basis for identification and verification of persons, and the documents serving as the basis for the establishment of a business relationship no less than five years after termination of the business relationship.

We retain the documents prepared with regard to a transaction on any data medium and the documents and data serving as the basis for the notification obligations for no less than five years after making the transaction or performing the duty to report.