Anti-Money Laundering Policy

1. Introduction

BitPayPro is committed to the highest standards of Anti-Money Laundering (AML) compliance and Counter-Terrorist Financing (CTF) practices. We maintain a comprehensive risk-based AML/CTF program designed to prevent, detect, and report suspicious activities that may involve money laundering, terrorist financing, or other financial crimes.

This AML Policy outlines our approach to regulatory compliance, customer due diligence, transaction monitoring, and reporting obligations. All users of BitPayPro services are subject to this policy and must comply with all applicable AML/CTF laws and regulations in their jurisdiction.

2. Regulatory Framework

BitPayPro operates in compliance with applicable AML/CTF laws and regulations in all jurisdictions where we provide services, including but not limited to:

• The Bank Secrecy Act (BSA) and USA PATRIOT Act in the United States
• Financial Action Task Force (FATF) Recommendations
• The Fifth Anti-Money Laundering Directive (5AMLD) in the European Union
• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act in Canada
• Local financial services and virtual asset regulations in operating jurisdictions
• Office of Foreign Assets Control (OFAC) sanctions programs

3.1 Customer Identification Program (CIP)

All BitPayPro users must complete identity verification before accessing trading services. Our CIP requires collection and verification of:

• Personal Information: Full legal name, date of birth, residential address, and nationality
• Government-Issued ID: Valid passport, national ID card, or driver's license with photo
• Proof of Address: Recent utility bill, bank statement, or government document (dated within 3 months)
• Selfie Verification: Live photo verification to confirm identity document authenticity

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required for high-risk customers, including:

• Politically Exposed Persons (PEPs) and their close associates
• Customers from high-risk jurisdictions identified by FATF
• Customers conducting large or unusual transactions
• Customers with complex ownership structures
• Customers engaged in high-risk business activities

EDD procedures include additional documentation requirements, source of funds verification, enhanced transaction monitoring, and senior management approval.

3.3 Corporate and Institutional Accounts

Business entities must provide additional documentation:

• Certificate of incorporation or business registration
• Articles of association or operating agreement
• Beneficial ownership information (25% or greater ownership)
• Board resolution authorizing account opening and trading
• Identification documents for authorized signatories
• Financial statements and proof of business activity

4.1 Automated Monitoring Systems

BitPayPro employs sophisticated automated monitoring systems that analyze all transactions in real-time for suspicious patterns, including:

• Unusually large transactions inconsistent with customer profile
• Rapid movement of funds, especially to high-risk jurisdictions
• Structured transactions designed to avoid reporting thresholds
• Patterns consistent with money laundering typologies
• Transactions involving sanctioned individuals or entities
• Mixing or tumbling services indicating potential laundering
• Transactions to/from darknet marketplaces or known illicit services

4.2 Red Flags and Risk Indicators

Our compliance team investigates transactions exhibiting red flags such as:

• Customer reluctance to provide required information or documentation
• Use of multiple accounts to conduct related transactions
• Frequent deposits followed by immediate withdrawals
• Transactions with no apparent economic purpose
• Inconsistencies between transaction patterns and stated business purpose
• Transactions involving recently created or dormant accounts
• Unusual trading patterns or off-market pricing

4.3 Suspicious Activity Reports (SARs)

When suspicious activity is identified, BitPayPro files Suspicious Activity Reports with relevant financial intelligence units and regulatory authorities as required by law. We maintain strict confidentiality regarding SAR filings and do not notify customers when reports are submitted. All SARs are filed within regulatory timeframes (typically within 30 days of detection).

5. Sanctions Screening and Compliance

BitPayPro maintains robust sanctions screening procedures to ensure compliance with international sanctions programs:

• Real-time Screening: All customers and transactions are screened against OFAC, UN, EU, and other sanctions lists
• Regular Database Updates: Sanctions lists are updated daily to ensure current compliance
• Blockchain Analysis: Cryptocurrency addresses are screened against known sanctioned entities and illicit services
• Geographic Restrictions: Services are restricted in sanctioned jurisdictions and high-risk countries

Any matches or potential matches are immediately investigated by our compliance team. Confirmed matches result in immediate account freezing and notification to relevant authorities.

BitPayPro maintains comprehensive records of all AML/CTF activities in accordance with regulatory requirements:

• Customer Records: All KYC documentation, verification records, and correspondence retained for minimum 7 years after account closure
• Transaction Records: Complete transaction history, including counterparties, amounts, timestamps, and blockchain data retained for 7 years
• Compliance Records: SAR filings, investigation reports, and risk assessments retained for 7 years
• Communications: Customer communications related to compliance matters retained for 7 years

Records are stored securely with access restricted to authorized compliance personnel and are available for regulatory inspection upon request.

7. Reporting Obligations

7.1 Currency Transaction Reports (CTRs)

BitPayPro files Currency Transaction Reports for fiat currency transactions exceeding applicable thresholds (typically $10,000 USD or equivalent) within required timeframes. Multiple related transactions are aggregated for reporting purposes.

7.2 Suspicious Activity Reports (SARs)

SARs are filed when we know, suspect, or have reason to suspect that a transaction:

• Involves funds derived from illegal activity
• Is designed to evade regulatory requirements
• Has no apparent lawful purpose
• Involves use of the platform to facilitate criminal activity

7.3 International Information Sharing

BitPayPro cooperates with international law enforcement agencies and regulatory bodies, sharing information as required by law or pursuant to valid legal process, including mutual legal assistance treaty (MLAT) requests.

8. Staff Training and Awareness

All BitPayPro employees receive comprehensive AML/CTF training:

• Initial Training: Mandatory AML compliance training for all new employees within 30 days of hire
• Annual Training: Yearly refresher courses covering regulatory updates, emerging risks, and case studies
• Role-Specific Training: Enhanced training for compliance, customer service, and risk management personnel
• Ongoing Education: Regular updates on typologies, red flags, and regulatory changes

Training completion is tracked and documented, with testing to verify comprehension and effectiveness.

9. Independent Testing and Audit

BitPayPro conducts regular independent reviews of our AML program:

• Annual independent audits by qualified third-party firms
• Ongoing monitoring and testing of AML controls and procedures
• Regular risk assessments to identify emerging threats and vulnerabilities
• Remediation plans for identified deficiencies with executive oversight
• Reporting to board of directors on AML program effectiveness

10. Risk-Based Approach

BitPayPro employs a risk-based approach to AML compliance, categorizing customers based on risk profiles:

• Low Risk: Verified retail customers from low-risk jurisdictions with standard transaction patterns
• Medium Risk: Customers with higher transaction volumes or from moderate-risk jurisdictions
• High Risk: PEPs, customers from high-risk jurisdictions, large volume traders, or complex business structures

Risk ratings determine the level of due diligence, transaction monitoring intensity, and review frequency applied to each customer.

Violation of these prohibitions may result in immediate account suspension or termination, asset freezing, and reporting to law enforcement authorities.

12. Account Restrictions and Closures

BitPayPro reserves the right to restrict or close accounts that:

• Fail to complete required KYC verification within specified timeframes
• Exhibit suspicious activity or red flags during monitoring
• Are subject to sanctions or regulatory restrictions
• Violate our AML Policy or Terms of Service
• Refuse to provide requested documentation or information
• Present unacceptable levels of AML/CTF risk

Account closures may be implemented immediately without prior notice when required by law or necessary to mitigate risk. Funds in closed accounts may be held pending regulatory clearance or investigation completion.

13. Policy Updates

This AML Policy is reviewed and updated regularly to reflect:

• Changes in applicable laws and regulations
• Emerging money laundering typologies and trends
• Guidance from regulatory authorities and FATF
• Results of independent audits and risk assessments
• Changes to our business model or services offered

Material changes will be communicated to users via email and platform notifications. Continued use of BitPayPro services constitutes acceptance of updated policies.

14. Contact Information

For questions regarding this AML Policy or to report suspicious activity, please contact: