Anti-Money Laundering Policy

Last updated: January 16, 2025

1. Introduction

Billinary is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures for preventing, detecting, and reporting money laundering and terrorist financing activities in accordance with EU directives and regulations.

As a facilitator of cryptocurrency-to-asset transactions within the European Union, we recognize our responsibility to maintain the integrity of the financial system.

2. Regulatory Framework

Our AML policy is designed to comply with:

  • EU Anti-Money Laundering Directives (AMLD5 and AMLD6)
  • Markets in Crypto-Assets Regulation (MiCA)
  • Financial Action Task Force (FATF) recommendations
  • Transfer of Funds Regulation (TFR) for crypto-asset transfers
  • Applicable national AML legislation in EU member states where we operate

3. Know Your Customer (KYC)

3.1 Customer Identification

Before initiating any transaction, all clients must complete our KYC verification process, which includes:

  • Identity verification: Valid government-issued photo identification (passport, national ID card, or driver's license)
  • Address verification: Recent proof of address (utility bill, bank statement, or official government correspondence dated within 3 months)
  • Selfie verification: A live photograph or video for identity matching

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied in higher-risk situations, including:

  • Transactions exceeding €15,000
  • Clients from higher-risk jurisdictions
  • Politically Exposed Persons (PEPs) and their associates
  • Complex or unusual transaction patterns
  • Transactions involving privacy-focused cryptocurrencies

3.3 Ongoing Monitoring

We conduct ongoing monitoring of client relationships and transactions to detect suspicious activity. This includes:

  • Regular review of client information and risk profiles
  • Transaction monitoring for unusual patterns or amounts
  • Screening against international sanctions lists and PEP databases
  • Blockchain analytics to assess the origin and destination of cryptocurrency funds

4. Source of Funds Verification

For all cryptocurrency transactions, we verify the legitimate source of funds through:

  • Blockchain analysis tools to trace the origin of cryptocurrency
  • Documentation of how the cryptocurrency was acquired (e.g., exchange records, mining records, employment income)
  • Assessment of wallet history and transaction patterns
  • Cross-referencing with known illicit addresses and darknet markets

5. Risk Assessment

We maintain a risk-based approach to AML compliance, categorizing clients and transactions into risk levels:

  • Low risk: Standard KYC, routine monitoring
  • Medium risk: Additional documentation, more frequent reviews
  • High risk: Enhanced due diligence, senior management approval, intensive monitoring

Risk factors include geographic location, transaction size, client profile, and the nature of the asset being purchased.

6. Suspicious Activity Reporting

All employees are trained to identify and report suspicious activities. When suspicious activity is detected:

  • The transaction is immediately flagged for review
  • Our compliance team conducts a thorough investigation
  • If warranted, a Suspicious Activity Report (SAR) is filed with the relevant Financial Intelligence Unit (FIU)
  • The client is not informed of the report ("tipping off" is prohibited)

7. Record Keeping

We maintain comprehensive records in accordance with EU requirements:

  • Client identification documents and KYC records — retained for a minimum of 5 years after the end of the business relationship
  • Transaction records — retained for a minimum of 5 years after the transaction
  • Internal reports and compliance documentation
  • All correspondence related to suspicious activity reports

8. Sanctions Screening

All clients and transactions are screened against:

  • EU consolidated sanctions list
  • UN Security Council sanctions list
  • OFAC (Office of Foreign Assets Control) sanctions list
  • National sanctions lists of relevant EU member states

Transactions involving sanctioned individuals, entities, or jurisdictions are prohibited.

9. Staff Training

All Billinary staff receive regular AML/CTF training covering:

  • Recognition of suspicious transactions and red flags
  • KYC procedures and documentation requirements
  • Reporting obligations and internal escalation procedures
  • Updates to relevant legislation and regulatory guidance
  • Cryptocurrency-specific AML risks and typologies

10. Refusal of Service

Billinary reserves the right to refuse or terminate a business relationship if:

  • The client fails to provide required KYC documentation
  • The source of funds cannot be satisfactorily verified
  • There are reasonable grounds to suspect money laundering or terrorist financing
  • The client appears on any sanctions list
  • The transaction involves a prohibited jurisdiction

11. Contact Our Compliance Team

If you have questions about our AML policy or compliance procedures, please contact us: