TBL

AML Policy

Applicable to Buying, Selling & Trading Bitcoin & Other Cryptocurrencies through TBL

Principles & Limits

  • TBL is vigilant in its monitoring and implementation of an effective Anti-Money Laundering Policy.
  • Anti-Money Laundering is at the core of TBL and we endeavor at all times to adhere to the systems and controls in place.
  • TBL will operate within the parameters of their AML Policy to mitigate the risks of TBL being used to facilitate the laundering of funds and/or proceeds of crime.
  • Senior Management is responsible for the oversight of compliance and ensuring the AML Policy is implemented when onboarding clients, receiving funds and transacting on behalf of clients.
  • TBL will adopt a risk-based approach towards the assessment and management of fraud, money laundering and terrorist financing risks.
  • The verification requirements and limits are regularly reviewed and updated when necessary.
  • Stringent identity and residence and source of funds verification is adopted when onboarding a new client and prior to any funds being received or transactions undertaken.
  • Established clients are monitored on an ongoing basis, including the receipt of funds from an authorised named account as well as the detection of accounts being used in a manner inconsistent with previous usage.
  • AML Policies and procedures are regularly reviewed by all staff involved in client activity and their obligations to report and monitor clearly outlined.
  • Suspicious activity is reported internally and onwards to the relevant law enforcement authorities.
  • Historical data is stored for an appropriate length of time in order to identify trends and perform any necessary retrospective reviews.
  • TBL will not undertake any Crypto Transactions or receive funds from any customers that have not registered and performed the onboarding and verification checks, however small.
  • TBL will only receive FIAT funds via bank transfer and from a specified and verified account in the name of the customer. TBL will not accept cash deposits or cash for crypto transactions.
  • Trade orders can be made electronically but these orders can only be confirmed via a voice call and can only be actioned thereafter. Hence, if a trade is not consistent with previous activity, a verbal consent and explanation will apply. 

Anti-Abuse

  • Brokers will attempt to generate a risk profile, trading style and crypto strategy (Know Your Client (KYC)) from clients and will therefore recognise any activity or requests beyond the parameters created. Any trades beyond these parameters will lead to verbal confirmation and a review/update of the strategy/profile.
  • We take steps to limit customers from trading beyond their informal limits by generating a profile for them and making them aware of these when necessary.
  • FIAT funds will only be accepted from a bank account corresponding to the name of the client and referenced with their name and account number.
  • TBL will not accept any third-party payments.
  • Funds received are for the purposes of Crypto trading only.
  • Enhanced Due Diligence is applied for any customers deemed to present a greater risk such as Politically Exposed Persons (PEPs).

Regulations

  • Although the Cryptocurrency activities of TBL are not deemed to require FCA regulation and TBL itself has no regulatory obligation to be an authorised firm, TBL maintains a stringent approach to AML policies and procedures. TBL has implemented the appropriated systems to meet AML legislative requirements and adopts a ‘best practice’ approach to ensure that these requirements are adhered to and the regulations enforced.
  • The various requirements for AML are covered under the following UK legislations:​

The Proceeds of Crime Act (POCA), as amended by the:

  • Serious Organised Crime and Police Act 2005 (SOCPA); and the
  • Proceeds of Crime act (Amendment) Regulations 2007;

The Terrorism Act 2000, as amended by the:

  • Anti Terrorism, Crime & Security Act 2001; and the
  • Terrorism Act (Amendment) Regulations 2007;
  • The Terrorism Act 2006;
  • The Money Laundering Regulations 2007; and
  • The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing. 

Customer Onboarding and New client verification

  • TBL will collate personal data (subject to in house Privacy Policy) for any new client, including:
  1. Name, Date of Birth, Address, contact telephone numbers, Email address, bank details from clients nominated bank (must be in their name), KYC due diligence.
  • In order for TBL to verify and authorise a new account, clients must submit 3 documents clearly displaying identification and proof of residency. At least 1 must be a valid Government issued ID. Acceptable examples are:
  1. Passport (double page);
  2. National ID Card (both sides);
  3. Driving License (both sides).
  • Acceptable examples of Proof of Residency IDs are:
  1. Current Account Bank Statement;
  2. Credit Card Statement;
  3. Loan-related documents from a bank;
  4. Utility Bill;
  5. Broadband home internet, landline bill;
  6. Tax return;
  7. Council Tax Bill;
  8. Government issued certificate of residency.
  • The 3rd compulsory document is a ‘Selfie’ of the client holding their ID document. Photo, name and address must be clearly displayed.
  • Proof of residency ID’s must be within 3 months and addressed to client’s name and home address.
  • Two Government issued IDs can be submitted along with the selfie and proof of address ID for any additional verification required.
  • Clients that are personally known to TBL or who set up via a personal face to face consultation will also need to submit the relevant documents in order to get their account authorised. In these circumstances it will be stipulated in the TBL in-house verification report.

Politically Exposed Persons

 Politically Exposed Persons or PEP are defined in Regulation 35 of the 2017 Regulations.

PEPs are defined as individuals entrusted with prominent public functions, such as heads of state, members of government, members of government bodies and ambassadors as well as members of their close family.

PEPs are classified to carry higher risks of Money Laundering so enhanced due diligence is required at both the on boarding process and on an ongoing basis.

TBL will take reasonable steps to identify if a prospective customer is a PEP or has political exposure prior to account activation.

If the individual is deemed to pose an additional risk their account will only be activated with the consent from Senior Management & Director.

In addition, the prospective customer will be required, at the on boarding stage to provide information, with supporting evidence of their source of wealth:

  1. Their current salary and other income; and
  2. Their liquid assets including cash and investment portfolio

Upon satisfaction of the additional due diligence criteria, their account may be activated.

The Management reserves the right to refuse the account or terminate the account if any additional or unknown risks are evident or materialise.

  1. TBL will take all reasonable precautions to ensure that fraud, financial crime and ML risks are mitigated by adhering to the requirements and procedures set out in this AML document and other supporting documents; (New Client Verification Report, Client Information Form, Transaction & Dialogue records).