1. This policy is the Anti Money Laundering (AML) Policy of Bitowo LTD (Bitowo). Any questions relating to this policy should be directed to legal@bitowo.com.
2. The purpose of this AML is to ensure not only that Bitowo are compliant with current legislation and requirements, but also to show that they take any form of illegitimate use of their services seriously.
3. Money laundering is where proceeds of crime are disguised so to give the appearance of a legitimate income. Bitowo will not tolerate any client abusing their services for such matters.
4. If Bitowo suspect any client is abusing their services for the purposes of money laundering, they reserve the right to suspend the users account and freeze any funds pending the outcome of an internal investigation. Bitowo reserve the right to report any suspicious activities to the police or relevant authorities without the client's knowledge.
5. In accordance with the current industry best practice guidelines, Bitowo have:
    1. Appointed a Money Laundering Reporting Officer;
    2. Established a risk based approach towards assessing and managing the money laundering risks to the business;
    3. Established and maintain risk based customer due diligence and obtain identification and proof of address in accordance with KYC (know your customer) which includes enhanced due diligence checks for customers which may present a higher risk, this will be determined at the sole discretion of Bitowo;
    4. Established and maintain risk based systems and procedures to monitor ongoing client activity;
    5. Have procedure for flagging and reporting suspicious activity.
6. Any client is subject to having their account frozen should Bitowo be suspicious of fraudulent activity or any activity, which may be related to money laundering.
7. As part of our AML policy, we ensure that any client agreeing to use our service, is also prepared to provide any of the following documentation in the event that a bank or government agency suspects illegal activity:
    1. Copy of Passport/ID
    2. Utility Bill
    3. Recent Bank Account Statement
8. If any of the above documents are requested, prior to sending them to us we require them to be certified as a true copy of the original by a Solicitor or Lawyer who must use their company stamp.
9. We require the documents to be sent to us in high quality colour format. We reserve the right to reject any documents, which do not comply with the above.
10. We reserve the right to require additional information at any time to verify the client's identification and any further information that may be required to satisfy the Money Laundering Regulations.