ComplianceBitvavo Anti-Money Laundering and Counter-Terrorist Financing Policy
The European Union has passed DIRECTIVE (EU) 2018/843 amending Directive (EU) 2015/84 both designed to combat money laundering and terrorism.
- Money Laundering can be defined as 'the conversion or transfer of property, knowing that such property is derived from criminal activity, or from an act of participation in such activity, for the purposes of concealing or disguising the illicit origin of the property, or assisting any person who is involved in the commission of such activity to evade the legal consequences of his action’.
Terrorist Financing can be defined as 'the wilful provision or collection, by any means, directly or indirectly, of funds with the intention that the funds should be used, or in the knowledge that they are to be used, in order to carry out terrorist acts'.
These Directives, together with regulations, rules and industry guidance, form the cornerstone of Bitvavo’s AML/CTF policy.
Whilst Bitvavo B.V. (Bitvavo) is currently unregulated and does not (yet) fall within the scope of AML/CTF obligations, Bitvavo aims to already implement systems and procedures that meet the standards set forth by the European Union. This aim reflects the board's desire to prevent money laundering and not be used by criminals to launder proceeds of crime.Anti-Money Laundering Policy
The Company's AML Policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.
The Company's AML Policy sets out the minimum standards which must be complied with and includes:
- Establishing and maintaining a risk-based approach to the assessment and management of money laundering and terrorist financing risks faced by Bitvavo;
- Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
- Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
- Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- Maintaining appropriate records for the minimum prescribed periods; and
- Providing training for and raising awareness among all relevant employees.
Bitvavo is prohibited by law from conducting business with individuals, entities and countries that appear on official Sanctions lists. Therefore all prospects or customers will be screened prior to offering any service, and on an ongoing basis, to ensure that the Bitvavo is authorized to have a business relationship with that customer.