AML KYC Policy

We (the company “Belfrics”) demonstrate our full commitment and support to high standards of compliance with the Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) requirements by establishing robust and comprehensive policy, procedures, processes and systems for the prevention and detection of money laundering and terrorist financing activities. The companies-wide AML/CFT program adopting a risk-based approach is subject to periodic reviews to ensure that it remains robust and complies with the requirements. The company will fully co-operate with the enforcement agencies and competent authority in the investigation of money laundering and/or financial crime. The Company protects itself from involvement in money laundering or suspicious activity by taking this key measure include having in place the following:

• Establishing AML/CFT policies and procedures.
• Implementing internal controls throughout its operations that are designed to mitigate risks of money laundering and Financing of Terrorism
• Performing know your customer (“KYC”) checks which is as per guideline(s) on all users
• Designate in country compliance officer(s) in each country(s) that the business is located as per the countries local regulatory requirements.
• Conducting an annual AML/CFT audit either internal or external audit services.
• Regular communication, supplemented with latest updates on AML/CFT and training programs through various channels were undertaken to raise staff awareness at all levels within the company and its affiliates.
• Record keeping of all identification/transaction details obtained for the purpose of customer identification as well as of all documents in accordance with statutory requirements; and not permit any trades to be made with incomplete account-opening information
• Screening of individuals and entities against sanction programs such as for e.g OFAC and also other related sanction programs to ensure that the company does not deal with any sanctioned individuals/entities;

The Policy (s) will be reviewed and approved by the Company’s Board. The Policy (s) once approved will be provided to all employees. Each employee will acknowledge and will need to understand. All policies and procedures will be reviewed and updated or revised as needed and periodic reviews will be performed. The company is committed to establishing and maintaining policies, controls and procedures to manage and effectively mitigate the risks of money laundering and terrorist financing. These policies will be regularly reviewed to ensure that they remain fit for purpose and will include:

• The risk management practices adopted by the company to prevent its business from being used for money laundering and/or terrorist financing.
• Customer due diligence requirements, including enhanced due diligence for those customers presenting a higher risk, such as Politically Exposed Persons (PEPs) and Senior Public Figures (SPF).
• Internal controls in relation to its senior management and staff members.
• The independent audit of its policies, controls and procedures.
• Record keeping.
• Monitoring compliance with its policies, controls and procedures and their communication to staff.

The Company has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML/CFT legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to the Company’s Board.

Reasonable procedures for maintaining records of the information used to verify a person’s name; address and other identifying information are required under this Policy. The following are required steps in the record keeping process:

• The Company is required to maintain a record of identifying information provided by the customer.
• Where the Company relies upon a document to verify identity, the Company must maintain a copy of the document that the Company relied on that clearly evidences the type of document and any identifying information it may contain.
• The Company must also record the methods and result of any additional measures undertaken to verify the identity of the customer.
• The Company must record the resolution of any discrepancy in the identifying information obtained.
• All transaction and identification records will be maintained for a minimum period of 7 years.

The company will appoint compliance officer (s) to receive disclosures about money laundering activity and be responsible for anti-money laundering activity. The compliance officer(s) will ensure that appropriate training and awareness is provided to new and existing staff and that this is reviewed and updated as required. The compliance officer(s) will ensure that appropriate anti-money laundering systems and processes are incorporated by the company. The compliance officer(s) will be in charge in directing the annual AML audit of the Company’s operations. The independent audit will be conducted by an independent thirdparty auditor, with working knowledge of compliance requirements.

All of the officers and employees of the Company are required to receive AML training either via online or manually at least annually. The Company will track the training progress of all employees and maintain documentation of each employee, the date of the AML training as well as a description of such training. New employees will receive appropriate AML training within 30 days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.

The documents used in opening an account relationship must be verified prior to establishing the account. Verification of identity will require multi-factor authentication, layered security and other controls to ensure a meaningful user identity confirmation process based on account size or other factors. The following are examples of verification methods the Company may use:

• Obtaining proof of address, such as a copy of a utility bill not more than 3-month-old or bank statement from the account holder to be not more than 3 months old.
• An OTP will be sent to the customer to verify the telephone number. In the event the OTP is not able to be sent to the customer, an introduction telephone call will be performed after the account relationship is open to validate the customer(s) contact details.
• Obtaining a financial statement for a business account.
• Comparing the identifying information with information available from a trusted third-party source, such as a credit report from a consumer-reporting agency and via in house Belrium KYC verification system.
• Analysing whether there is logical consistency between the identifying information provided, such as the customer’s name, street address, ZIP code, telephone number, date of birth, and social security number (logical verification).
• Utilizing knowledge-based challenge questions.
• Obtaining a notarized copy of an individual’s birth certificate or a business’ certificate of incorporation sealed with an apostille for valid identification.
• When the type of account increases the risk that the Company will not be able to verify the true identity of the customer through documents is confirmed the account will be closed.
• A clear photo(s) should be taken, e.g. a selfie together the customer holding their dentification document.

There are different account levels, with deposit and withdrawal limits that apply to each level.

Please note: There are some cases where you will still be required to provide extra documentation.

Certain of this limit apply to each verification level.

Note* the limited provide are subject to change as per the regulator requirements and/or changes in company policy. The company reserves the rights to do so

Note* The limits provided are for both Fiat Currency and Cryptocurrency Transactions, or/and for transactions that have a Mix of both Fiat Currency and Cryptocurrency. Please be advised this is a combined limit. No separate limit is to be provided as of this moment

8. CUSTOMER IDENTIFICATION

It is the Company’s policy to ensure that it has reasonably identified each customer who uses the Company’s virtual currency exchange platform. Users may be identified using a variety of methods.

8a) Proof of Identification:

8a.1) For individuals:

• Name (to indicate name as per the official Identification document).
• Date and place of birth.
• The client age has to be above eighteen (18) or the legal age for entering legally binding contracts under applicable laws. However, for there is an exception for the Singapore whereby the client has to be above the age of (21) or the legal age for entering legally binding contracts under applicable laws.
• A clear Photo(s) should be taken e.g. a selfie (this is to validate the authenticity of all/any of the photo identification provided) by the customer, with the customer holding the ID document. This applies to all customer of the company.
• Proof of Residence and mailing address need to be not more than 3 months.
• However, in relations to countries/regions/locations in which the PO box is their only address available. Further due diligence will be taken in which additional documents will need to be provided as provided below.
• Official issued identification number (e.g., passport number, social security number, employee identification number or individual taxpayer identification number).
• Copy of valid photo identification of the principal(s) involved with the account e.g. Driving license (if contains photograph of individual), armed forces identification, passport, alien identification card/work permit) in which will include the front and back of the identification document; (note* in addition this is a compulsory requirement).
• A copy individual’s birth certificate (this is a non-photo-based document is some/all) countries.

For all Passports/Identity Documents ensure the following

• The document is valid and shows the issue and expiry dates.
• The photograph is clear and all features are visible.
• The page showing signature is included.
• The place of issue and passport number details are included and are clearly legible.
• Nationality details are included.
• For national ID card, driver’s license (if contains photograph of individual), Armed Forces ID Card both the front portion and the back portion of the card will need to be provided.
• A copy individual’s birth certificate (this is a non-photo-based document is some/all) countries in which has to be sealed with an apostille for valid identification.

Proof of residential address documents must show the name of the customer opening the account (documents showing joint names for couples are acceptable). Further the address has to be the same on all the received documents and need to be not more than 3 months.

This is a Compulsory document need to be not more than 3 months old.

• Bank or building society statement from a financial institution which is, in the opinion of the company (in its absolute discretion), reputable.

And one of the followings in which need to be not more than 3 months old:
Valid, full driving license (unless already provided as proof of identity)

• Utility bill (such as gas, water, electricity, although NOT a mobile phone bill).
• Television license.
• Home or motor insurance policy document or certificate (or equivalent).
• Council tax (or equivalent) bill.
• Solicitor’s letter confirming house purchase; proof of previous address must be supplied (only acceptable for customer in between property
  moves).
• Rental Tenancy Agreement which has been officially stamped, signed and verified.
• Letter or any document from the university/college/or any agency which shows.
  hostel/residence has been facilitated to the customer which shows the current address not more than 3-month-old

8a.2) Customer with PO Box Address*

a) This is a Compulsory document need to be not more than 3 months old. Further the PO Box address has to be the same on all of the received documents:

• Bank or building society statement from a financial institution which is, in the opinion of the company (in its absolute discretion), reputable.

b) Note: For individual customer whom, the PO box is their only address available. It is Compulsory to provide a minimum of two of the
followings in which need to be not more than 3 months old:

• Utility bill (such as gas, water, electricity, although NOT a mobile phone bill).
• Television license
• Home or motor insurance policy document or certificate (or equivalent).
• Council tax (or equivalent) bill.
• Solicitor’s letter confirming house purchase; proof of previous address must be supplied (only acceptable for customer(s) in between property
  moves).
• Rental Tenancy Agreement which has been officially stamped, signed and verified
• Letter or any document from the university/college/or any agency which shows
  hostel/residence the current PO Box address.

8a.3) Customer who Share an Address with Another Person*

If you share an address with another person, like your parents or a housemate, you can ask them to sign an affidavit and submit it along with the following:
a) Passports/Identity Documents of the parents or a housemate as per (8a.1) For individuals.

b) A valid proof of address document as below which need to be not more than 3 months old:

• Utility bill (such as gas, water, electricity, although NOT a mobile phone bill).
• Television license.
• Home or motor insurance policy document or certificate (or equivalent).
• Council tax (or equivalent) bill.
• Solicitor’s letter confirming house purchase; proof of previous address must be supplied (only acceptable for customer(s) in between property moves).
• Rental Tenancy Agreement which has been officially stamped, signed and verified.
• Letter or any document from the university/college/or any agency which shows.
• hostel/residence has been facilitated to the customer which shows the current address.

c) With the signed and certified copy of the affidavit (Please click here for the affidavit form).
d) For customer with PO Box Address please refer to point (8a.2) for information.

8a.4) For Customer(s) Foreign Resident, Not a Local Citizen*

a) Valid government-issued residence permit/visa, which should be one of the following types and document need to be not more than 3 months old:

• Proof of Residency
• Business or
• Permanent or
• Refugee or
• Spousal or
• Study or

b) This is a Compulsory document need to be not more than 3 months old. Further the PO Box address has to be the same on all of the received documents:

• Bank or building society statement from a financial institution which is, in the opinion of the company (in its absolute discretion), reputable.

c) A valid proof of identity document and document need to be not more than 3 months old:

• Utility bill (such as gas, water, electricity, although NOT a mobile phone bill).
• Television license.
• Home or motor insurance policy document or certificate (or equivalent).
• Council tax (or equivalent) bill.
• Solicitor’s letter confirming house purchase; proof of previous address must be supplied (only acceptable for customers(s) in-between property moves).
• Rental Tenancy Agreement which has been officially stamped, signed and verified
• Letter or any document from the university/college/or any agency which shows
• hostel/residence has been facilitated to the customer(s) which shows the current address.

d) For customer(s) with PO Box Address please refer to point (8a.2).

Politically Exposed Persons*

Politically exposed person” (PEP) is a term describing someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.

Senior Public Figure is defined as a senior official in the executive, legislative, administrative, military or judicial branches of a government, whether or not elected, a senior official of a major political party, or a senior executive of a government-owned or government-funded corporation, institution or charity. A “Senior Public Figure” also includes any entity that has been formed by or on behalf of a Senior Public Figure, in which the Senior Public Figure is a beneficial owner of at least twenty-five percent of the entity. In addition, a “Senior Public Figure” includes the immediate family of a Senior Public Figure and any close associate or relative of a Senior Public Figure. A close associate is a person who is widely and publicly known to maintain an unusually close relationship with and able to conduct financial transactions on behalf of a Senior Public Figure.

The company cannot take on such an individual or their family member, close relative or known a person of the PEP or SPF as a customer without the consent from the Company’s Board or/and compliance officer(s).

In addition, the prospective customer will be required, at customer take on stage, to provide information, with supporting evidence of their source of wealth:

• Their current salary and other income; and
• Their liquid assets (including cash and investment portfolio).
• Further documents as per 8a.1 to 8a.4 (whichever is applicable) For individuals.

There are different account levels, with deposit and withdrawal limits that apply to each level.

Please note there are some cases where you will still be required to provide extra documentation upon request by the company.

10a) Proof of Identification:

• Business name in full a per the company registration document
• Name of businesses representative for the account
• A copy of business’ certificate of incorporation sealed with an apostille for valid identification
• A clear Photo(s) should be taken e.g. a selfie (this is to validate the authenticity of all/any of the photo identification provided) by the customer. This applies to all customer(s) of the company.

The address of the customer’s principal place of business and, if different, the customer’s mailing address. If the customer has a local address different from its principal place of business, the local address. This should be facilitated with the anyone or more documents a below a minimum of 2 documents are required from the list as below). The address verification documents need to be not more than 3 months.

• Utility bill (such as gas, water, electricity, although NOT a mobile phone bill) which need to be not more than 3 months old.
• Stamped and signed Tenancy agreement (shows the name of the customer opening the account (documents showing joint names for couples are acceptable), and the address.
• Any other document that can indicate the location of the respective business e.g. business account bank statement, loan and etc in which need to be not more than 3 months old.
• Official issued identification number of the principal(s) involved with the account (e.g., passport number, social security number, employee identification number or individual taxpayer identification number).
• Copy of valid photo identification of the principal(s) involved with the account e.g. Driving license (if contains photograph of individual), armed forces identification, passport, alien identification card) in which will include the front and back of the identification document; (note* in addition this is a compulsory requirement.

Each of the following:

• Business Certificate of incorporation and memorandum and articles of association sealed with an apostille for valid identification.
• Latest annual return (optional for new startups).
• Latest 3-month bank statement (for new start-ups) which indicates as proof the total capital injected into the company.
• Latest statutory report and accounts.
• Current shareholder and director registers.
• Resolution of the Board of Directors to open an account and identification of those who have authority to operate the account.
• Full CDD documentation on each director (see “for individuals” above).
• Full CDD documentation on each ultimate beneficial owner of more than 20% of the company’s share capital. Where there are corporate shareholders, documentation confirming the identity of the ultimate individual beneficial owners must be provided.

10b) For partnerships*

Including each of the following:

• Registration certificate (where applicable) or any business registration document (such as a tax registration document, including VAT certificate)
• Copy partnership deed
• Full CDD on all individual partners (see “for individuals” above)

10c) For charities, foundations or trusts and etc*

This category of customer is particularly high risk. Charities, foundations and trusts and etc operate with different structures based on the jurisdiction in which they are based in. Hence to this moment the company does not provide any services to religious, sporting, social, cooperative and professional societies and Charities, foundations and trusts.

The company/employees cannot/will not take on such an individual as a customer without the consent from the Company’s Board or/and compliance   officer(s) in writing.

Note* additionally Customer due diligence procedures will be followed to determine the beneficial owners of corporate or business customer. This would include determining if the customer is an agent of or on behalf of another; obtaining information about the structure or ownership of a customer who is a legal entity that is not publicly traded in the respective region; and where the customer is a trustee, obtaining information about the trust structure, determining the provider of the funds and any persons who have control over the funds or the power to remove the trustee. Kindly verify with the Company’s Board or/and compliance officer(s) before taking any action in on the matters as mentioned above

Certain of this limit apply to each verification level.

Note* the limited provide are subject to change as per the regulator requirements and/or changes in company policy. The company reserves the rights to do so

Note* The limits provided are for both Fiat Currency and Cryptocurrency Transactions, or/and for transactions that have a Mix of both Fiat Currency and Cryptocurrency. Please be advised this is a combined limit. No separate limit is to be provided as of this moment

For the request to Increase of Deposit and Withdrawal Limits for Corporate bodies, the customer is required to furnish the requirements as below:

• Up to date/Latest annual return
• Latest Profit and Loss (P&L) statement
• Latest 3-month bank statement (for new startups)

Kindly note the request to increase the Deposit and Withdrawal Limits is subject for approval.

The Limit as below:

Note* the limited provide are subject to change as per the regulator requirements and/or changes in company policy. The company reserves the rights to do so

Note* The limits provided are for both Fiat Currency and Cryptocurrency Transactions, or/and for transactions that have a Mix of both Fiat Currency and Cryptocurrency. Please be advised this is a combined limit. No separate limit is to be provided as of this moment

The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Internal controls will be implemented so that an ongoing monitoring system is in place to detect such activity as it occurs. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary.

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.

The Compliance Officer will initially make the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, he or she will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

The Compliance Officer will maintain a copy of the filing as well as all back up documentation. The fact that a filing has been made is confidential. No one, other than those involved in the investigation and reporting should be told of its existence. In no event should the parties involved in the suspicious activity be told of the filing. The Compliance Officer may inform the Company’s Board of the filing and the underlying transaction

Note* In addition, the company reserves the right to request additional documents if/when required for KYC/AML/CFT purposes in its absolute discretion.

Note* This document and any other document attached or affiliated to this document is subject to change by company as per the regulator requirements and/or changes in company policy. The company reserves the rights to do so.