AML / CTF and KYC policy
Purpose:
The AML policy of AlfaBit Group (hereinafter referred to as the "Policy") is designed to ensure compliance with the requirements of the Kyrgyz Republic regarding anti-money laundering and counter-terrorism financing (AML/CFT). The Policy takes into account the provisions of Law No. 12 "On Virtual Assets," Law No. 87 "On Combating the Financing of Terrorism and Legalization (Laundering) of Criminal Proceeds," Law No. 81 "On Amendments to Certain Legislative Acts in the Field of Virtual Assets," as well as the decrees of the National Bank of the Kyrgyz Republic and FATF recommendations.
1. Scope
- The Policy applies to the following operations:
- Wallet with additional options,
- Cryptocurrency exchange,
- Payments through the Pay service,
- Asset storage,
- Internal transfers.
2. Client Identification (KYC)
In accordance with Laws No. 12 and No. 81, AlfaBit Group performs the following KYC procedures:
Client Identification and Verification:
Clients are required to provide identity documents (passport or ID card), address verification, and information about beneficial owners for legal entities. AlfaBit Group reserves the right to request a re-verification of the user’s identity at any time using photo and/or video verification.
All information containing personal data of users is processed and stored strictly in accordance with the Company’s data processing and storage policy and may only be disclosed as provided by law.
In adherence to commonly accepted KYC standards, AlfaBit Group takes measures to identify and restrict the provision of its Service to politically exposed persons (PEPs).
Screening Against Sanction Lists:
In accordance with Law No. 81, the Company is required to screen clients against sanction lists and freeze assets of sanctioned individuals.
Risk-Based Approach:
AlfaBit Group applies enhanced verification measures and reserves the right to restrict access for clients from certain countries with high risk, including but not limited to: North Korea, Iran, Myanmar, Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d'Ivoire, Croatia, Democratic Republic of the Congo, Haiti, Kenya, Lebanon, Mali, Monaco, Mozambique, Namibia, Nigeria, Philippines, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam, Yemen, the United States of America, Afghanistan, Bosnia and Herzegovina, Eritrea, Ethiopia, Guyana, Iraq, Lao People's Democratic Republic, Libya, Somalia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine, the United Kingdom, Mainland China, Singapore, Hong Kong, Canada, Cuba, Uzbekistan, Crimea, Sevastopol, Donetsk, and Luhansk regions.
3. Transaction Monitoring (KYT)
1. Transaction Analysis:
All transactions carried out by users are screened for risks using blockchain analytics. According to AlfaBit Group's internal AML procedures, additional scrutiny is applied to transactions involving anonymous cryptocurrencies and those with exclusively transit characteristics.
2. Requirements for User Applications:
- To ensure the security of all participants in the process, the Service does not support payments involving third parties
- All contact information and other personal data provided by the user to the Service must be up-to-date and completely accurate.
3. Freezing of Funds in Case of Suspicious Transactions:
Transactions associated with prohibited assets and those that appear suspicious are blocked, and a report is filed with the financial control and supervisory authority of the Kyrgyz Republic (in accordance with Law No. 81).
4. Internal Control Program
In accordance with Laws No. 81 and No. 87, AlfaBit Group has implemented an internal control program that includes:
- Appointing a responsible employee to ensure compliance with the legal requirements for anti-money laundering and counter-terrorism financing,
- Training employees on AML measures,
- Continuous monitoring of transactions for compliance,
- Client data protection and cybersecurity programs.