AML

The AJUBIT anti money laundering policy

AML Policy

Anti Money Laundering (AML) Policy

Financial institutions and closely related entities (such as e.g. cryptocurrency exchanges) experience often attempts of money laundering and terrorist financing. Money laundering is defined as the process where the identity of the proceeds of the crime are so disguised that it gives the appearance of legitimate income. Terrorist financing is defined as the process of providing support to individual or group terrorists. Without direct terrorist financing, such activities as fund-raising, use and possession and funding arrangements also falls under the definition of terrorist financing.

AjuBit Limited (the AjuBit) pays thorough attention to any activities that may be considered as money laundering or terrorist financing. AjuBit AML policy is designed to prevent money laundering by complying with Seychelles AML legislation along with Global obligations including the need to have adequate systems and controls in place to mitigate the risk of being used to facilitate the financial crime.

The laws and regulations include, but not limited to: “Customer Due Diligence for Banks” (2001) and “General Guide to Account Opening and Customer Identification” (2003) of Basel Committee of banking Supervision, Forty + nine Recommendations for Money Laundering of FATF, USA Patriot Act (2001), Prevention and Suppression of Money Laundering Activities Law of (1996).

To minimize and mitigate the risk of money laundering and/or terrorist financing, AjuBit implemented effective internal measures and procedures:

• Establishment of the identity of AjuBit customer;
• Assessment of risk;
• Monitoring of the customer’s activities, Incoming/outgoing transfer; and
• Rejection of restricted countries; blacklisted, Greylisted and High-risk countries;
• Reporting of suspicious activities to respective authorities if necessary or asked hereby;

Establishment of the identity
Before any customer can access and benefit of AjuBit services, identity of such customer has to be established. For AjuBit to be able to establish the identity of its customer, AjuBit must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of AjuBit pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. AjuBit retains a right to re-establish the identity of the customer in cases where AjuBit Limited sees it fit and in relation to that, request additional data/documents/information or renew previously submitted.

Customer’s identification information will be collected, stored, shared and protected strictly in accordance with AjuBit’s Privacy Policy and related regulations.

Assessment of risk
To mitigate and minimize the risks, AjuBit has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which AjuBit Limited is exposed, and take the appropriate mitigation measures in accordance with the level of risk. Risk based approach also allows to pay most of the attention to the higher risk and allocate most of the resources for mitigation of such risks.

Monitoring
To get to know its customers, AjuBit performs ongoing and retrospective monitoring. Monitoring performed by AjuBit intends not to only to get to know the customer, but also to notice unconformities taking into comparison information submitted to AjuBit by the customer or obtained by AjuBit during establishment of the identity and such customer’s actual activities using AjuBit services and to catch any attempts of fraudulent, illegal or unlawful activity.

AjuBit uses both manual and automated solutions to track its customers’ transactions. AjuBit may use other measures on case by case basis.

Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures taken to ensure no money laundering or terrorist financing activity is performed. AjuBit is entitled to request additional information/data/documents in relation to any transaction and the customer must follow the such request.

Outgoing Banking Transfers
All Outgoing Wire Transfers user must be KYC verified and additionally require the following information for verification and security reasons:

• Purpose of payment
• Supporting documentation (source of fund)
• Information on the receiving party
• Confirmation that the client did indeed request the transfer submitted.
• If client documentation supplied being verified and confirmed legitimate, the Outgoing Wire Transfer can be executed.

Suspicious Transactions:
Detecting a suspicious transaction is based on the following transaction situations:

• Out of the ordinary transaction based on the clients’ transaction history
• If the beneficiary or originating account name is found to be associated to any form of illegal financing or financial fraud during security checks
• If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer
• If the transfer is destined for a black listed or sanctions country
• If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame If it is felt that a transaction is deemed suspicious, it is required that the processing of the transaction be discontinued and reported.

Declined Transactions:
Outgoing Wire Transfers should be declined in any one of the following circumstances:

• Insufficient documentation
• Beneficiary account held in a black listed or sanctions country
• The beneficiary bank account name must be same as AjuBit account name, for any mismatches Declined the transactions

Incoming Banking Transfer
All Incoming Wire Transfers user must be KYC verified and additionally require the following information for verification and security reasons:

• Source of funds
• Supporting documentation (clearly confirming the purpose of payment and the remitting party)
• Information on the remitting party

Suspicious Transactions:
A suspicion may be based upon a transaction or activity, which is inconsistent with a customer’s known legitimate business, activities or lifestyle or with the normal business for that type of product/service.

Detecting a suspicious transaction can be based on the following transaction situations:

• Out of the ordinary transaction based on the Clients transaction history
• If the remitting account name is found to be associated to any form of illegal financing or financial fraudulent activity
• If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer
• If the transfer is destined for a black listed or sanctions country
• If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame.

Declined Transactions:
Incoming Wire Transfers should be declined in any one of the following circumstances:

• Insufficient documentation
• Remitting account name is a listed individual/corporate
• Remitting account held in a Black Listed or sanctions Country
• Unable to prove source of funds
• Value exceeds Individuals means and resources

AjuBit do not process any Blacklisted and Greylisted countries Incoming/Outgoing banking transfer which describe bellows:

FATF Blacklists and Greylists countries:
The Financial Action Task Force (FATF) blacklist (sometimes referred to as the OECD blacklist) is a list of countries that the intragovernmental organization considers non-cooperative in the global effort to combat money laundering and the financing of terrorism. By issuing the list, the FATF hopes to encourage countries to improve their regulatory regimes and establish a global set of AML/CFT standards and norms.

The current FATF blacklist countries: 
1) North Korea 
2) Iran

The current FATF Greylists countries:
Albania, The Bahamas, Barbados, Cambodia, Iceland, Jamaica, Mauritius, Mongolia, Myanmar, Nicaragua, Panama, Syria, Yemen and Zimbabwe.

AjuBit also not process Incoming/Outgoing transfer any “High-risk Third countries and Non-cooperative jurisdictions for tax purposes listed by Europe Union” which describe bellows:

High-risk Third countries:
Afghanistan, The Bahamas, Barbados, Cambodia, Democratic People's Republic of Korea (DPRK), Iran, Iraq, Jamaica, Mauritius, Myanmar, Nicaragua, Panama, Syria, Trinidad and Tobago, Uganda, Vanuatu, Yemen, Zimbabwe

Non-cooperative jurisdictions for Tax purposes:
The Economic and Financial Affairs Council of the EU (ECOFIN) adopted a revised EU list of non-cooperative jurisdictions for tax purposes (the EU blacklist). Following this latest revision, the EU blacklist includes the following jurisdictions: 

American Samoa, Anguilla, Barbados, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands, Vanuatu.

AjuBit also not process Incoming/Outgoing transfer where Bitcoin is Banned or illegal! 

Countries where Bitcoin is banned or illegal:
Algeria, Bolivia, Dominican Republic, Ghana, The Republic of Macedonia, Quatar, Vanuatu.

Reporting to the Authorities
Following its AML Policy and the applicable legal acts, AjuBit, when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. AjuBit will not disclose any information about such report to have been made and will not address any questions in relation to that.

Compliance officer
AjuBit has the assigned Compliance officer who is responsible for implementation of AjuBit AML policy, including but not limited to, of the above listed activities.

Data Storage
The storage of customer due diligence (“CDD”), transaction documents, wire transfer records, internal and external suspicion reports and compliance monitoring reports are retained and stored electronically via an online storage facility.

Each client has a folder created under their username on the opening of their AjuBit account. All KYC documentation and security check reports are saved in a sub folder for compliance documentation. Documentation in regards to payment transactions is stored in a further sub folder for payments & reports. Documentation can be retrieved from the online storage facility as and when required by the AjuBit administrators and authorized users, via login details requiring a password for access to the data.