AML - CryptoCurrency Payments - B2BinPay

Anti-money laundering policy (AML)
In order to protect the assets of our customers and to ensure the compliance with international trade
standards, B2BinPay (hereinafter – the «Company») operates exclusively in accordance with the legislation on
combating illicit money laundering and countering the terrorism financing. To monitor the accordance with
legal requirements and recommendations of FATF, the Company has established a Compliance department
developing Anti-money laundering and Know your customer (AML / KYC) procedures, obligatory for all
employees of the Company and determining the policy of engagement with any person which have registered
on the Company’s website (hereinafter – the «Customer»). Compliance
Department is intended to ensure that all the operations of the Company are consistent with the international
standards to combat money laundering and all the documents provided by the Customer are up-to-date and
comply with relevant legal requirements. By performing the registration on our Website the Customer makes
complete and unconditional acceptance of the policy conditions, agrees with the following rules and
undertakes to observe them:
1. The crediting of Assets to the Customer’s Trading Room is allowed only after the verification of the
Customer’s identity. For all Customer’s the Company has developed a simplified verification process which
involves mandatory confirmation of Customers E-Mail, phone number and optionally 2FA verification.
However, for the corporate and institutional Customers the enhanced verification is required (please look at
the KYC policy).
2. The withdrawal of Assets is carried out only to the account that belongs to a person identified as a
Customer of the Company (the owner of a Trading Room). The withdrawal of Assets to third parties is
prohibited. Internal transfers between the Company’s customers are also forbidden.
3. The Company is obliged and has the right without obtaining prior consent to share with financial
institutions and law enforcement agencies any information about the Customer, as required by applicable
law, and the Customer gives the Company its consent to these actions. In order to comply with this paragraph,
the Company holds a records about Customer’s transactions during five years at least.
4. The Customer undertakes to follow the legislation, including international one, aiming to combat
illicit trafficking, financial fraud, money laundering and legalization of funds obtained by illegal means. The
Customer undertakes to use its best effort to avoid direct or indirect participation in illegal financial activities
and any illegal transactions using the Company’s Website and Services.
5. The Customer guarantees the legal origin, legal ownership and the right to use the Assets
transferred to its Account.
6. In case of the evidence of suspicious transactions at the Customer’s account, cash replenishments
from untrusted sources (for example, the data of Assets’ sender and Trading Room’s owner is different) and
/ or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company
reserves the right to conduct an internal investigation, to block or close the Customer’s Trading Room or any
Account, cancel any payment or trading order and to suspend operations on the Accounts before the end of
the official investigation. When making the decision the Company is guided by the provisions of the applicable
law, FATF recommendations or by common practice.
7. The Company has the right to request additional information about the Customer if the method of
withdrawal Assets is different from the depositing method. The Company also reserves the right to block the
Customer’s Trading Room or any Account during the investigation if the Customer refused to provide the
additional information requested by the Company.
8. In the course of investigation the Company has the right to request additional copies of documents
confirming the identity of the Customer, as well as copies of bank cards used to replenish the account,
payment documents and other documents confirming the lawful possession and legal origin of funds. The
Company also has the right to demand the provision of original documents for review in case of any doubts
from Company’s side.
9. The Company does not provide Services to the persons who located at the jurisdictions that are
identified by the FATF as high risk and non-cooperative jurisdictions having strategic AML/CFT deficiencies.
10. The Company’s refuse to perform the operations that from Company’s point of view are
considered to be a suspicious, using of preventive measures (such as blocking or closing of a Customer’s
Trading Room or any Account) is not the reason for civil liability of the Company for failure to fulfill obligations
to the Customer.
11. The Company is not obliged to inform the Customer or other persons about the measures taken
to fulfil the AML/CFT legislation. Also the Company is not obliged to inform Customers or other persons about
any suspicions, about the reasons of refuse of execution of a Customer’s trading order, of refuse to open the
Account, need for providing Customer’s documents, etc.
12. This anti-money laundering and know your customer policy is an integral part of the Agreement,
located at the Website. Non-compliance with this policy can be a ground for termination of the Agreement
on Company’s sole discretion.