ANTI-MONEY LAUNDERING POLICY AND MANUAL

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A. Introduction

MYBITSTORE is an infrastructure provider for the exchange of cryptocurrency. It operates the Mybitstore App which allows for users to exchange cryptocurrency providing them with a reliable Cryptocurrency trading service. As financial services provider it is becoming necessary for us to understand the clients we serve. We value the trust and opportunity to serve our Clients, and therefore take the task of offering security along with proper legal compliance seriously. In this regard, we perform Know Your Customer (KYC) and Anti Money L Laundering (AML) procedures in adherence with the laws of Ghana and international best practices.

B. Purpose and Overview

The purpose of our AML Policy is to establish the general framework for the fight against money laundering and other financial crimes. Successful participation in this fight by the financial sector requires an unprecedented degree of global cooperation between governments and financial institutions. Our Company is committed to reviewing our AML strategies and objectives on an ongoing basis and to maintaining an effective AML programme. We are committed to high standards of AML compliance and require management and employees to adhere to these standards in preventing the use of our products and services for money laundering purposes. Adherence to this policy is absolutely fundamental for ensuring that all of our entities, regardless of geographical location, comply with applicable anti-money laundering legislation. We are required and committed to adhere to minimum standards of anti-money laundering compliance based on the applicable anti-money laundering laws and regulations. Our AML programme is formulated and directed under the auspices of the Board of Directors. However, it is the responsibility of all employees to keep ill-gotten funds out of our institution. The Company is committed to complying with AML/KYC obligations in order to actively prevent any transaction that otherwise facilitates criminal activity or terrorism. The Company will, therefore, formulate and implement internal controls and other procedures to deter criminals from using its facilities for money laundering, thus ensuring that it meets its obligations under the law. The internal control measures include:

Programmes to assess the risks related to money laundering;
The formulation of control policy concerned with issues of timing, degree of Control, areas to be controlled, responsibilities and follow-ups, to combat money laundering and terrorist financing;
Monitoring programmes in relation to unusually large transactions; enhanced due diligence with respect to persons and businesses carrying high risks, including politically exposed Enhanced due diligence on persons in jurisdictions that do not have adequate AML/KYC regimes;
Providing employees, including the Compliance Officer, with training on customer due diligence and the recognition and handling of suspicious transactions, etc;
Making the employees to be aware of the provisions of the AML/KYC laws and regulations and the manual of compliance formulated by the Company, pursuant to those laws

C. Anti-Money Laundering Reporting Officer’s Designation and Duties

The Company shall appoint a responsible official as an Anti-Money Laundering Reporting Officer (AMLRO) who will operationally report to the Board in accordance with section 41(1) (b) of the Anti-Money Laundering Act, 2008 (Act749) as amended, Regulation 5(1) of L.I. 1987 and Part A 1.0 of the Company of Ghana and Financial Intelligence Centre AML/KYC Guideline for Non-Bank Financial Institutions . He/she shall be equipped with the relevant competence, authority and independence to implement the Company’s AML/KYC compliance programme. He or she shall be equipped with the relevant competence, authority and independence to implement the Company’s AML/KYC compliance programme. The duties of the AML Reporting Officer shall include but not limited to the following:

Developing an AML/KYC Compliance Programme;
Receiving and vetting suspicious transaction reports from staff;
Filing suspicious transaction reports with the competent/supervisory authority;
Ensuring that the compliance programme is implemented;
Coordinating the training of staff in AML/KYC awareness, detection methods and reporting requirements; and

Serving both as a liaison with relevant competent/supervisory authorities and a point-of-contact for all employees on issues relating to money laundering and terrorist financing.

D. Data Protection

The Company is registered under the Data Protection Act of Ghana, Act 2012 (Act 843). To this end, the Company is mindful of and shall be guided in its handling and processing of personal by all the eight thematic areas of the Act.

The Company is registered under the Data Protection Act of Ghana, Act 2012 (Act 843). To this end, the Company is mindful of and shall be guided in its handling and processing of personal by all the eight thematic areas of the Act.
Lawfulness of Processing Minimality. Personal data may only be processed if the purpose for which it is to be processed is necessary, relevant and not excessive.
Specification of Purpose. A data controller who collects personal data shall collect the data for a purpose which is specific, explicitly defined and lawful and is related to the functions or activity of the person.
Compatibility of Further Processing w3with Purpose of Collection. Where a data controller holds personal data collected in connection with a specific purpose, further processing of the personal data shall be for that specific purpose.
Quality of Information. A data controller who processes personal data shall ensure that the data is complete, accurate, up to date and not misleading, having regard to the purpose for the collection or processing of the personal data.
Openness. The Company shall ensure that the data subject is aware of the nature, purpose and consequences of breach of data usage. Where the said data is already in the Public domain, the data subject is not protective of it and that the Company bears no liability for its usage.
Data Security Safeguards. The Company shall take appropriate security measures to prevent unauthorized access, alteration, disclosure or destruction of personal data. It shall include adopting enhanced security measures to the Company’s data processors.
Data Subject Participation. The Company may disclose information to our agents, advisors, service providers for the following reasons:

E. KYC PROGRAMME

Know Your Customer’’ (KYC) requirement entails obtaining full particulars of the identity of a customer and having adequate knowledge of the purpose for which the customer desires to establish a business relationship with a financial institution. Having adequate knowledge of a customer and applying it to all transactions initiated by the customer is an effective way of avoiding being used to launder the proceeds of crime and recognizing suspicious activities..

a. Customer Acceptance Policy

The Company will not establish a business relationship until all relevant counterparties to the relationship have been identified and duly ascertained. Once an on-going business relationship has been established and the normal operation confirmed, any inconsistent activity would be investigated to determine whether there is a suspicion of money laundering.

b. The Requirement to Obtain Identification Evidence

The first requirement of knowing your customer for money laundering purposes is that the Company should be satisfied that a prospective customer is who he/she claims to be. The Company shall not carry out, or agree to carry out, any financial business to a customer or potential customer, unless the Company is certain about who that person actually is. The Company shall require the user to furnish the following details (which shall be subject to change):

First Name
Last Name
National Identification , Passport Number driver’s license.
Date of Birth
Email Address

The collected information shall be run against existing databases using internal and other third parties to ensure that the users who are on boarded are not listed adversely in any AML cases. All cards to be accepted shall be verifiable. A photo ID that cannot be verified shall not be accepted in any form unless the customer could furnish another valid photo ID to support the initial one. The information obtained should clearly establish that a person of that name exists and that the applicant is that person.

F. Monitoring, Recognising and Responding to Suspicious

All transactions of customers shall be monitored to ensure that they are consistent with the Company’s knowledge of the customer(s) involved, their businesses and risk profile performed on them during the onboarding stages. Continuous monitoring of high risks accounts shall be conducted. When any staff of the Company detects any “red flag” or suspicious money-laundering activity, the staff is required to promptly report to the AML Reporting Officer who shall commence an immediate investigation. Upon the establishment of a prima facie case, a Suspicious Transaction shall be recorded within twenty-four hours of knowledge of same by the AML Reporting Officer.

a. Suspicious Transaction

There are numerous types of suspicious transactions, reflecting the various ways in which money launderers operate. For the purpose of this manual, a suspicious transaction may be defined as one which is unusual because of its size, volume, type or pattern or otherwise suggestive of known money laundering methods, such as a transaction that is inconsistent with a customer’s known, legitimate transactions and or lacks that lacks an obvious economic rationale. The AML Reporting Officer would train staff to a level that would enable them to monitor, recognize and respond appropriately to suspicious transactions. The AML/KYC Compliance Officer shall supervise the monitoring and reporting of suspicious transactions. The Company would be alert to the various patterns of conduct that have been known to be suggestive of money laundering and maintain a checklist of such transactions which would be disseminated to the relevant staff.

b. Reporting Process

When any staff member detects any ‘’red flag’’ or suspicious money laundering activity, he or she should promptly institute a review under the supervision of the Compliance Officer who will then issue a suspicious transaction report (STR) .

c. Filing A Suspicious Transaction Report (STR)

Where the Compliance Officer knows, suspects or has reason to believe that a transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity;

A transaction is designed, whether through structuring or otherwise, to evade the reporting requirements;
A transaction has no business or apparent lawful purpose or is not the type in which the customer would normally be expected to be engaged in; or
National Identification , Passport Number driver’s license.
A transaction involves the use of the institution to facilitate a criminal activity,

the Compliance Officer shall file a suspicious transaction report. The Compliance Officer should not base the decision to file a suspicious transaction report solely on either the transaction falls above the prescribed threshold but should file such a report in all circumstances where transactions raise reasonable suspicion of criminal, corrupt, or terrorist activities. The Compliance Officer should report suspicious transactions and collect and retain the supporting documentation.

G. Detection of Suspicious Transaction

Where a transaction is detected to be suspicious the Company shall take immediate steps to investigate where need be.

H. An Audit Function to Test the System

There shall be an Independent audit function to test the AML system. This periodic audit test will help review the AML/KYC framework with a view to determine its adequacy, effectiveness and completeness.

I. AML/KYC Record Keeping

The Company shall maintain all necessary records on transactions, both domestic and international; all records obtained through CDD measures, account files and business correspondences and results of any analysis undertaken for at least seven (7) years following completion of the transaction. This will enable the Company to comply swiftly with information requests from competent authorities . To accomplish this, document retention policies would be set and procedures would be established for maintaining AML/KYC records. In establishing document retention policy, the Company is guided by both statutory requirements on the one hand and commercial considerations, on the other.The broad categories of AML/KYC-related records are

Customer identification and verification documents.
Transaction records.
Suspicious transaction reports, together with supporting documentation.

AML/KYC -related records may be maintained by way of original documents, stored in computerized or electronic form, subject to the provisions of the law .The Compliance Officer or other designated officer shall be responsible for ensuring that all AML/KYC records are maintained properly and kept for not less than 7 years before they are sent to the archives.

J. Employee Education and Training Programme

The Company shall hold frequent strategic and operational meetings to discuss and communicate KYC/AML policies and to ensure that employees and management are on the same page in regards to such policy and action. Channels of communication shall be kept open through training to ensure that employees can easily and efficiently raise concerns to management regarding suspicious activity around KYC/AML both internally and externally.

K. Administrative sanctions against staff that violate AML regulations

Any member of Staff that is suspected or found to have contravened any of the AML regulations like tipping-off, aiding and abetting Money Laundering activities, etc, shall be made to appear before the disciplinary committee of the Company. Such a person when found guilty shall be sanctioned according to the rules of the Company, and may not be insulated from further civil and criminal liabilities under the AML Act (Act 749)

L. Penalty for Money Laundering infractions under the AML Act

A person who is found liable for abetting money laundering activities under the provisions of the AML Act 2008 (Act 749) as amended, commits an offence and is liable on summary conviction to a fine of not more than five thousand penalty units or to a term of imprisonment of not less than twelve months and not more than ten years or to both.

M. Conclusion

In the preparation of this Policy and Manual, deliberate efforts have been made to capture and adopt industry best practice. This document shall be reviewed biennially. Nevertheless, should there be a major change in the AML regime whether globally, in the sub region or nationally that calls for adoption, the Company shall co-opt that relevant information into this document. We value your trust, and we shall ensure your safety and stability by ensuring that our services are not misused or abused by malicious parties to the detriment of genuine users.