AML POLICY

BALTBIT Sp. z o.o. is a company duly incorporated in the Republic of Poland, registered company number 525570981, registered office address: Hoża Street 86/210, 00-682 Warszaw, Poland, hereinafter – the ‘BaltBit’.

BaltBit is authorized by the Polish Revenue Administration Chamber (https://www.gov.pl/web/national-revenue-administration/about-us) to conduct virtual currency business activity (certificate number 2401-CKRDST.4225.305.2023, Reference number RDWW-808).

Since virtual currencies are the main business focus of BaltBit and one of the most dynamic, fast changing, and innovative parts of the today’s financial services landscape, BaltBit pays special attention to the identification, prevention, and mitigation of risks BaltBit may pose while rendering services related to virtual currencies and virtual currencies transactions.

To prevent money laundering, terrorism financing and other financial crimes while using BaltBit services, BaltBit has established robust anti-money laundering and counter terrorism financing policies and procedures based on high ethical standards in financial transactions and compliance with applicable laws and regulations.

BaltBit internal AML rules and procedures are established in line with the BaltBit domestic and supranational mandatory binding requirements and recommendations:

  • The Act of 1st March 2018 on Counteracting Money Laundering and Terrorist Financing of the Republic of Poland, with the latest updates,
  • The Act of 19th August 2011 on Payment Services of the Republic of Poland, with the latest updates,
  • Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU,
  • Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC,
  • Sanctions and SDN lists:
    • Poland General Inspector of Financial Information (GIIF) issued Sanctions lists,
    • EU consolidated Sanctions and SDN lists,
    • OFAC Sanctions and SDN lists.
  • European Union and other supranational AML/CTF organization binding enforcements and recommendations (e.g., FATF, OFAC, UN).

BaltBit for ‘Know Your Customer’ (‘KYC’) purposes collects certain minimum customer identification information from each customer, who applies for BaltBit services.

The minimum information the customer, should provide for KYC purposes is: full name (First, Last, Middle, Former (if any)), residential address (including country, postal code, state, and city), date of birth, phone number, e-mail address.

For KYC and customer due diligence purposes BaltBit requests the following minimum of documents:

  • government issued identity document: valid international passport, or national Identity Card (ID) with MRZ code, and documents proving residence address – utility bill, bank statement etc. (mobile phone bills, medical bills, receipts for purchases, insurance statements, as well as screenshots of any document proving the address, shall not be accepted).

This is not an exhaustive list of information and documents requested for KYC and due diligence purposes. BaltBit reserves the right at any time to request any additional information and documents to get full understanding of the customer, as well as, to dispel any doubts and suspicious of money laundering, terrorism financing or other financial crimes, or even attempts of such illegal activity.

The customer should provide BaltBit with the requested documents/information without hesitation, at the latest within 5 (five) business days since the date of the documents/information request. BaltBit retains the right to decline the customer if requested documents/information are not submitted in time.

Each prospective BaltBit customer should undergo mandatory sanctions and PEP screening, which includes checking against global watchlist of businesses, organizations, individuals, and government agencies to protect against fraud and illicit activity.

BaltBit maintains an-ever changing list of non-cooperative jurisdictions:

  • Afghanistan
  • Bahamas
  • Barbados
  • Botswana
  • Cambodia
  • Crimea
  • Cuba
  • Democratic People’s Republic of Korea (DPRK)/North Korea
  • Ghana
  • Iran
  • Iraq
  • Jamaica
  • Lebanon
  • Libya
  • Mauritius
  • Myanmar/Burma
  • Nicaragua
  • Pakistan
  • Panama
  • Russian Federation
  • Syria
  • Trinidad and Tobago
  • Ukraine’s Luhansk region
  • Ukraine’s Donetsk region
  • Uganda
  • United States of America
  • Vanuatu
  • Venezuela
  • West Bank and Gaza Strip
  • Yemen
  • Zimbabwe
  • Belarus

BaltBit in no case establish business relationship and does not provide services to the customers included in any watchlist, surrounded by negative adverse media, being residents or otherwise connected to any of the non-cooperative jurisdictions, intended to use BaltBit services in conjunction with prohibited industries.

BaltBit has established adequate systems and tools to identify, control and mitigate the risks BaltBit may pose, including robust customers’ verification and due diligence rules and procedures, money laundering and terrorism financing risk assessment and controls, transactions’, and customers’ activity monitoring toolset. BaltBit monitors its customers’ transactional activity on ongoing manner, ensuring timely identification of suspicious activity.

BaltBit has built highly skilled and seasoned AML team which is duly trained in all applicable aspects of anti-money laundering and terrorism financing and overall compliance requirements of BaltBit.

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