Financial Crime Compliance Statement
Introduction
BTC-X, LLC (old name ITM-UA, Private Enterprise), that provides BTC-X.PRO mobile trading platform (hereafter, BTC-X.PRO) recognises the adverse effect of financial crimes and is committed to conducting its activities with integrity, respecting its regulatory, ethical and social responsibilities to:
- protect customers, staff (permanent and contractors), and others with whom we do business;
- support governments, regulators, and law enforcement in wider economic crime prevention. BTC-X.PRO will not tolerate any deliberate breach of financial crime laws and regulations (e.g. bribery, corruption, money laundering & terrorist financing, sanctions, tax evasion or market abuse) that apply to our business activity.
BTC-X.PRO has a dedicated global Financial Crime function, which sits within Compliance. The Financial Crime function facilitates effective and efficient financial crime risk management by providing expert support and oversight to the business in the jurisdictions of operations.
Governance
Chief Compliance Officer (CCO) is responsible for group-wide adherence to applicable AML and Financial Crime regulations and obligations in the jurisdictions of operations. In addition, CCO is responsible for establishing and maintaining AML program to identify, assess, monitor and manage risks related to Money Laundering, Terrorist Financing and other financial crime related matters. CCO is supported by MLROs of relevant jurisdictions who have overall responsibility for establishing and maintaining effective financial crime controls and perform day-to-day AML related duties.
Policies and Procedures
BTC-X.PRO's Financial Crime Compliance policy framework covers six key risk areas:
- anti-money laundering & counter-terrorist financing (AML&CTF);
- sanctions
- anti-bribery & corruption (ABC);
- anti-tax evasion (ATEF);
- fraud and
- market abuse,
Our holistic approach to financial crime allows us to identify and manage relevant synergies and connections between the key risk areas. All policies and procedures are accessible by all staff at any time. In addition, all policies are:
- designed to ensure that all employees, businesses and legal entities comply with extra-territorial obligations and relevant regulations applicable in jurisdictions of BTC-X.PRO operations;
- approved by the Board of Directors and applicable to all entities within BTC-X.PRO group;
- are subject to an annual review cycle to ensure their effectiveness, which provides senior executive management with the necessary assurance regarding the financial crime control framework.
Mitigation and Management of Financial Crime Risks
BTC-X.PRO has developed and implemented a comprehensive set of measures to mitigate, identify and manage financial crime risks. These measures include:
- BWRA and AML risk assessment;
- A robust KYC process;
- Training and awareness for BTC-X.PRO staff;
- PEP and Sanctions controls;
- SARs;
- Anti-Bribery and Corruption;
- Anti-fraud.
Country of Residence
BTC-X.PRO's AML/CTF Policy sets out BTC-X.PRO's risk appetite with regard to client's onboarding. BTC-X.PRO does not accept clients who are residents in countries deemed to be above risk appetite. These include:
- Afghanistan
- Albania
- Algeria
- Angola
- Bangladesh
- Barbados
- Bolivia
- Burkina Faso
- Burundi
- Cambodia
- Cayman Islands
- Central African Republic
- Chad
- China
- Congo
- Cote D'ivoire
- Cuba
- Ecuador
- Egypt
- Equatorial Guinea
- Eritrea
- Ghana
- Guinea
- Guinea-Bissau
- Guyana
- Haiti
- Iran
- Iraq
- Jamaica
- Jordan
- Lao PDR
- Lebanon
- Libya
- Mali
- Morocco
- Myanmar
- Nepal
- Nicaragua
- North Korea
- North Macedonia
- Pakistan
- Panama
- Qatar
- Saudi Arabia
- Senegal
- Somalia
- South Africa
- South Sudan
- Sudan
- Syria
- Trinidad and Tobago
- Tunisia
- Uganda
- Vanuatu
- Venezuela
- Yemen
- Zimbabwe
BTC-X.PRO also does not accept any clients from disputed or unrecognized territories as they do not produce recognized official ID documents. These include:
- Crimea (Ukraine region)
- Donetsk People's Republic (DPR)
- Luhansk People's Republic (LPR)
- Nagorno-Karabakh Republic (Republic of Artsakh)
- Palestine
- Pridnestrovian Moldavian Republic
- Republic of Abkhazia
- Republic of China (Taiwan)
- Republic of Kosovo
- Republic of Somaliland
- Republic of South Ossetia
- Sahrawi Arab Democratic Republic
- Turkish Republic of Northern Cyprus
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