Last Modified: January 19th, 2016
At BitOasis, we have implemented the best AML-CFT practices across our business. Our state-of-the-art compliance regime and AML-compliant software are meticulously tailored to complement the requirements of the Know Your Customer (KYC) principles within the digital assets ecosystem.
BitOasis is fully committed to adapt and improvise upon the internationally accepted principles of compliance and adhere to the prospective local as well as international laws and regulations which may govern the industry, while reflecting the relevant recommendations issued by bodies such as Financial Action Task Force (FATF), Wolfsberg Group, etc. on preventing the utilization of the digital assets for criminal purposes.
Accordingly, we have taken the necessary procedures and control measures to provide the optimum support against the fight of money laundering and financial terrorism.
BitOasis is also committed to continually fulfilling its Anti-Money Laundering (AML) obligations to its local and foreign associates, and correspondent banks that may sometimes require due diligence information on accounts and transactions covered under the guidelines and recommendations of the FATF.
BitOasis also, pledges to examine and maintain its AML procedures and control on an on-going basis.
To ensure the continuity of high standards of AML Compliance, our internal audit regime monitors, and tests the Compliance Program through random examination of the relevant processes; on a quarterly basis; accordingly, the findings are documented and reported to the board of directors.
The customer’s identity is verified and screened against international blacklists and sanctions lists before accepting a transaction of AED 2,000 and above or equivalent in foreign currency. Customer identity is also verified for unusual/suspicious transactions regardless of the amount. 'Know Your Customer/Customer Due Diligence procedures and guidelines’ are scrupulously adhered to. The transactions amounting less than the aforementioned threshold are allowed only for customers holding a local bank account and a locally registered phone number.
In the case of transactions amounting to AED 20,000 or above per week, the customer is mandated to furnish a valid proof of source of funds and also the supporting document(s) to substantiate the purpose of a transaction which may vary on a case to case basis. BitOasis does not provide a channel or a platform to conduct any on behalf transaction whatsoever. However, the Compliance regime can solicit such indenture even for certain cases below the stated threshold if deemed necessary.
Enhanced due diligence is conducted when transactions appear to be potentially suspicious on the basis of well-defined red flag indicators. Our client relationship staff ensures to seek additional identification documents or documentary proof of source of the fund as deemed appropriate by the Compliance regime. In such cases, an in-depth due diligence is conducted outlining the transaction behavior, and the regular surveillance of remittances that may reveal potentially suspicious activities.
On an ongoing basis, our platform enables us to analyze the transaction behavior of the users while monitoring the volumes and frequency of their transactions.
In addition to the above, our tools enable us to identify the red flags based on different parameters we use for risk profiling of our customer base such as:
All client relationship staff liaising with the client(s) for increased limits requests and overseeing subsequent remittances in the client’s account is required to report any potentially suspicious or unusual transactions to the Compliance Officer using our internal reporting system.
All Staff is required to detect and report unusual/potentially suspicious transactions to Compliance Officer who will, in turn, conduct an in-depth investigation, and take an appropriate action before documenting such transactions or activities in the form of STRs and SARs respectively and file them for the perusal of auditors and prospective regulator(s).
Within a month of joining BitOasis, the employee is trained on AML-CFT procedures with follow-up training scheduled yearly and in the case of significant amendments to the policies; whichever occurs first. This training covers employees with customer contact and those authorized to execute/facilitate cash and non-cash transactions.
The training is also provided to staff that are:
The HR function essentially confirms and documents the reliability of candidates considered for employment with BitOasis before on boarding and again within a period of twenty-four (24) months of their tenure therein. The latter documentation consists of an attestation by the respective supervisor stating that there is no reason to believe the person is not reliable in terms of the local Laws and Regulations.
All records including customers’ identification documents, transaction data, and any other related documents are retained as long as they hold an account with BitOasis and subsequently for a minimum period of five years after the closure/redundancy of the account.
All customer records and transactional information is kept confidential at all times, and the customers are not intimated if their transactions are considered suspicious and being reported to Compliance Officer internally, or are being filed as STRs or SARs. Non-Compliance of the aforementioned invites criminal charges against BitOasis, its Directors, Management, and its employees at fault.
Internal Audit tests the effectiveness of the Compliance Regime and performs random checks on its key responsibilities. All findings and observations are discussed with the Compliance Officer and are reported to the board of directors.