Anti-Money Laundering Policy.
The Buhtaobmena service warns users against trying to use the service to launder money obtained by criminal means, financing terrorism, illegal actions of any kind, as well as from using the service to purchase prohibited goods and services.
Money laundering is the concealment of an illegal source of funds by converting them into cash or investments that look legitimate.
General provisions
To prevent operations of an illegal nature, the Service establishes certain requirements for all Applications created by the User:
The sender and recipient of the Payment under the Application must be the same person. Using the services of the Service, transfers in favor of third parties are strictly prohibited.
All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be up-to-date and completely reliable.
It is strictly forbidden to create Applications by the User using anonymous proxy servers or any other anonymous connections to the Internet.
This anti-money laundering policy (hereinafter referred to as the “AML Policy”) describes the procedures and mechanisms used by the Buhtaobmena Service to counter money laundering. The Buhtaobmena Service adheres to the following rules:
do not do business with known criminals and/or terrorists;
not to process transactions that are the result of known criminal and/or terrorist activities;
not facilitate any transactions associated with known criminal and/or terrorist activities;
has the right to restrict or prohibit the use of all or part of the services for citizens of such countries as Afghanistan, Bosnia and Herzegovina, USA, Democratic People’s Republic of Korea, Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People’s Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine.
Verification Procedures
The Buhtaobmena service establishes its own verification procedures within the anti-money laundering standards – the Know Your Customer (KYC) policy.
Users of the Buhtaobmena Service undergo a verification procedure (provide a state identification document: a passport or an identification card). The Buhtaobmena service reserves the right to collect Users’ identification information for the purposes of implementing the AML Policy. This information is processed and stored strictly in accordance with the Privacy Policy and the Personal Data Processing Policy of Buhtaobmena.
Also, the Buhtaobmena Service may request a second document to identify the User: a bank statement or a utility bill not older than 3 months, which indicates the full name of the User and his actual place of residence, the service also has the right to request a photo / video verification of the client, if there are suspicions about the dishonesty of the information provided.
The Buhtaobmena service verifies the authenticity of documents and information provided by Users and reserves the right to receive additional information about Users who have been identified as dangerous or suspicious.
If the User’s identification information has been changed or his activity seemed suspicious, then the Buhtaobmena Service has the right to request updated documents from the User, even if they have been authenticated in the past.
Responsible for AML Policy Compliance
The person responsible for compliance with the AML Policy is an employee of Buhtaobmena, whose responsibilities inсlude ensuring compliance with the AML policy, namely:
collection of identification information of Users and its transfer to the responsible agent for the processing of personal data;
creating and updating internal policies and procedures for writing, reviewing, submitting and storing all reports required by existing laws and regulations;
monitoring of transactions and analysis of any significant deviations from the normal activities of Users;
implementation of a records management systеm for storing and retrieving documents, files, forms and logs;
regular updating of the risk assessment.
The AML Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.
Transaction monitoring
Monitoring of the User’s transactions and analysis of the received data is also a tool for risk assessment and detection of suspicious transactions. If money laundering is suspected, the Buhtaobmena Service controls all transactions and reserves the right to:
report suspicious transactions to the appropriate law enforcement authorities;
etc
