AML жана KYC саясаты

Draft for legal review. This is a working example and has not been approved. Items in [brackets] need confirming.

Last updated: [date]

1. Purpose

Coinbit is committed to preventing money laundering, terrorist financing and sanctions evasion. This summary describes our programme under the Law of the Kyrgyz Republic "On Countering the Financing of Terrorist Activities and Legalization (Laundering) of Criminal Proceeds" (No. 87 of 6 August 2018), the Law "On Virtual Assets", and related regulations.

2. Compliance officer

We have appointed a compliance officer responsible for this programme and for contact with the competent authorities: [name / email].

3. Client identification and verification

We identify and verify every client before settlement.

• Individuals: a valid government-issued identity document, proof of address, and a liveness or in-person check.
• Companies: registration documents, details of directors and authorised signatories, and identification of ultimate beneficial owners.
• Source of funds and wealth: evidence where the size or nature of the trade calls for it. [Thresholds to be confirmed.]

4. Risk-based approach

We assess each client's risk and apply enhanced due diligence to higher-risk clients, including politically exposed persons and clients linked to higher-risk jurisdictions.

5. Sanctions screening

We screen clients and beneficial owners against the sanctions lists that apply in the Kyrgyz Republic, and against [other lists adopted by policy].

6. Transaction monitoring

We screen virtual asset transactions using approved blockchain analytics tools, and we monitor for unusual patterns. For transfers, we obtain and retain the required originator and beneficiary information. [Thresholds to be confirmed.]

7. Reporting

We report suspicious and other reportable transactions to the State Financial Intelligence Service of the Kyrgyz Republic as the law requires. We do not tell clients when a report has been made.

8. Record-keeping

We keep identification data and transaction records for at least five years.

9. Refusal of service

We may refuse, delay or terminate any relationship or transaction where we cannot complete due diligence or where we suspect illicit activity.

10. Training

Staff receive regular training on these obligations.