AML POLICY

LAST UPDATE: 23.01.2023

BT-Wallet

It is the policy of QUARO FINANCE Ltd (The Company) to reach for the highest level of integrity and prohibit and actively prevent money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the «placement» stage, where the cash generated from criminal activities is converted into monetary instruments, such as cryptocurrencies, or deposited into accounts at financial institutions. At the «layering» stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the «integration» stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cryptocurrency is rarely deposited into exchange accounts, the crypto exchange industry is unique in that it can be used to launder cryptocurrency obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations will be reviewed by our compliance officer and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business

AML Compliance Person Designation and Duties

  • 1. Our Commitment

    BT-Wallet -is committed to preventing, detecting and deterring fraud, money laundering and terrorist financing. BT-Wallet has a no-tolerance fraud, money laundering and terrorist financing policy and actively engages the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), the Royal-Canadian Mounted Police (RCMP) and other law enforcement agencies when users engage in activities contrary to this policy. BT-Wallet is a reporting entity under current Canadian anti-money laundering (AML) and counter terrorist financing (CTF) legislation and is registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

  • 2. Compliance Program

    BT-Wallet -is committed to preventing, detecting and deterring fraud, money laundering and terrorist financing. BT-Wallet has a no-tolerance fraud, money laundering and terrorist financing policy and actively engages the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), the Royal-Canadian Mounted Police (RCMP) and other law enforcement agencies when users engage in activities contrary to this policy. BT-Wallet is a reporting entity under current Canadian anti-money laundering (AML) and counter terrorist financing (CTF) legislation and is registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

    • Written policies and procedures: these list our responsibilities under the law, and what we are doing to meet them;
    • A documented Risk Assessment: a document that describes and assesses the risk that our business could be used to launder money or finance terrorism;
    • The appointment of a Compliance Officer: the person who is ultimately responsible to develop and maintain our AML and CTF compliance program;
    • AML Compliance Effectiveness Reviews: testing and reporting completed either annually or every two years that assesses how well our compliance program is working; and
    • Training: conducted at least annually to ensure that everyone understands his or her roles and responsibilities.

  • 3. Operational Compliance

    In addition to our documented program that consists of the five elements, BT-Wallet also operates in a FINTRAC compliant manner. This includes:

    • To accept as clients only those individuals and legal entities whose identity and ownership can be adequately ascertained and whose activities can reasonably be established to be legitimate,
    • To not knowingly provide any form of financial services to clients who money is believed to be derived from the proceeds of crime of activity that violate sanctions, or whose money is believed to be intended for use for illegal activities,
    • To cooperate with regulators, law enforcement agencies and financial intelligence units in accordance with applicable law,
    • To review new product and services and delivery channels and associated systems, acquisitions, mergers, joint ventures, policies and procedures, as well as significant changes to any of them, to ensure that the associated AML/CTF risk is within BT-Wallet risk appetite and that appropriate internal controls are in place to mitigate identified risks.
    • Collecting and recording client identification and know your customer (KYC) information, in accordance with legal requirements, prior to granting users access to our platform,
    • Reporting certain types of transactions to regulators and government agencies including, but not limited to, transactions suspect to be originating from or connected to terrorist, money laundering, tax evasion, fraud or other illegal activities,
    • Maintaining appropriate registration and licensing, and
    • Keeping all user and transaction records and sanction related documents in a manner required by applicable law.