AML/KYC Policy

PREFACE

There is a wide-range oflegislation and regulations which as a financial services firm, we must complywith. In all cases not specified in this policy, Vikingbond OÜ followsthe guidelines set by the Money-Laundering and Terrorist Financing PreventionAct (passed 26.10.2017).AML/KYC agreement is a legalbinding agreement between the Company and its Customers, made to ensure Qualityand Safety of use on the Websites. Both Individual (private persons) andBusiness (corporate and institution) Customers are subjected to this agreement.In order to protect the Assetsof our customers and to ensure the compliance meet the international tradestandards, Vikingbond OÜ (hereinafter “The Company”) isoperating exclusively in accordance with the legislation on combating illicitmoney laundering and countering the terrorism financing. To monitor theaccordance with the legal requirements and recommendations of FATF, we haveestablished a Compliance department developing Anti-Money Laundering and KnowYour Customer (AML / KYC) Procedures, those procedures are obligatory for allemployees and determining The Company policy of engagement with any person orcompany which have registered on www.bitibond.com website or the exchangeplatform app.bitibond.com (hereinafter “Websites”) in order to receive services(hereinafter “Customer”, “Customers”).Compliance Department main objective isto ensure all Company operations are consistent with the internationalstandards to combat money laundering and all the documents provided by theCustomer are up-to-date and comply with relevant legal requirements.

ESTONIAN LAW​

Estonian Cryptocurrency Exchanges are definedin the Estonian law as Providers of Alternative Means of Payment, licensed asan Estonian Financial Institution by holding a Financial Activity License fromthe Estonian Financial Intelligence Unit (FIU), which is the Anti-Money Laundering (AML) authority in Estonia with the ability to grant, revokeand supervise financial activity licenses. The AML and KYC requirements of theservice providers are subject to are set forth in the Estonian Money-Launderingand Terrorist Financing Act and other legal guidelines given by the EstonianMinister of Finance. Any breach of our procedures relating to the prevention ofmoney-laundering and the combating of terrorist financing will be dealt withseverely and may be treated as gross misconduct. No financial sector businesscan consider itself immune from the possibility of being used to furtherfinancial crime and we must carefully consider risks to our business and deviseappropriate procedures with due regard to these risks. Such procedures willenable us to comply with the applicable legislative and regulatoryrequirements. Vikingbond OÜ complies with the highest standards of legislation of theRepublic of Estonia in the field of Anti-money laundering and countering thefinancing of terrorism politics. In order to establish business relationswithin the framework of Cryptocurrencies acquiring cooperation, all customersmust be verified using AML & KYC procedures.

TERMS OF USE

By performing theregistration on our Websites, the Customer makes complete and unconditionalacceptance of the policy conditions, agrees with the following rules, andundertakes to observe them:

1. All Customers of the Websites agrees to go thru PEPScreening, AML, KYC Verification process made by a reputable third-partysoftware which the Company have agreement with, provide the required KYCdocuments prior to completion of the financial relationship from both sides. Incase the Customer would like to receive more information about the companyplease do not hesitate to contact us.

2. All Crypto based exchange transactions on the Blockchainwill be monitored by reputable KYT (Know Your Transactions) third-partysoftware, this software will check the origin of the Crypto in case of Customerexchanging Crypto to Fiat on the Websites, preforming a “Sell” Transaction. incase of any alerts by the software the Company will inform the relevantauthorities. The Websites may also check the Customer wallet to ensure itsorigin are not of any suspicious activity. In case the Customer would like toreceive more information about the company please do not hesitate to contactus.

3. All Customers of the Websites are treated in the samemanner, therefore the AML (Anti-Money Laundering) requirements are the same.difference in requirements may vary in accordance with Account Levels. TheCompany may, based on its sole discretion, request additional information fromCustomers. The specific requirements and applied limits are specified at thebottom of this AML & KYC Policy.

4. Customers who successfully pass the KYC which isassociated with the relevant Account Level will obtain all benefits foreseenfor this account Level. The Websites will try to perform KYC procedures as soonas possible, however in separate circumstances it may take several days.

5. Corporate and Institutional Customers are recognized asCustomers in the level of Account Level 3, they also may be subjected for enhancedKYC measures on a Case by Case basis depending on Country of incorporation,Business activity, etc.

6. Even though the Company holds European Licenses allowingprovision of exchanging and storing Digital Currencies (hereinafter“Cryptocurrencies”) to its Customer, All Customers are liable to check thelocal legislation and/or rules regarding Cryptocurrencies in their own countryand agrees not to indemnify, under any circumstances, the Company or any of itsemployees, nor hold The company or any of its employees responsible, should theCustomer fail to act based on or comply with their country of origin orresidency rules and legislations in regards to the provision ofCryptocurrencies service by the Company. The Customer will hold fullresponsibility to check and act on the local rules, legislations andrestrictions in which the Customer is subjected to including but not limitedto, investments tax, profits tax, any other government laws, tax, legislationor restrictions.

7. The Company requests of any additional documents and/orinformation should be provided by the Customer. Filling of respective KYCquestionnaire may also be an obligatory requirement under Websites soledecision. The Customer agrees with such requirements of the Websites and agreesto follow them.

8. The Company is obliged and has the right withoutobtaining prior consent to share with financial institutions and lawenforcement agencies any information about the Customer, as required byapplicable law, and the Customer gives the Websites its consent to theseactions. In order to comply with this paragraph, The Company shell hold recordsabout Customer’s transactions during period of five years.

9. The Customer undertakes to follow the legislation,including international one, aiming to combat illicit trafficking, financialfraud, money laundering and legalization of funds obtained by illegal means.The Customer undertakes to use its best effort to avoid direct or indirectparticipation in illegal financial activities and any illegal transactionsusing the Websites and Services.

10. The Customer guarantees the legal origin, legalownership and the right to use the Assets transferred to its wallets or bankaccounts.

11. In case of the evidence of suspicious transactions inthe Customer account, cash replenishments from untrusted sources and / or anyactions with attributes of fraud (including any refunds or cancellation ofpayments), the Company reserves the right to conduct an internal investigation,to block or close the Customer’s Account, cancel any payment or exchangingorder and suspend operations on the Customer’s account until the end of theofficial investigation. When making the decision the Company is guided by theprovisions of the applicable law, FATF recommendations or by common practice,based on its sole discretion.

12. The Company reserves the right to request additionalinformation from the Customer if the method of withdrawal Assets is differentfrom the depositing method. The Company also reserves the right to block theCustomer’s Account during the investigation should a Customer refuse to providethe additional information requested by the Company.

13. In the course of investigation the Company has theright to request additional copies of documents confirming the identity of theCustomer, including but not limited to, copies of bank cards used to replenishthe account, payment documents, other documents confirming the lawfulpossession and legal origin of funds. The Company also reserves the rights todemand the provision of original documents for review in case of any doubtsfrom Company’s side.

14. The Company does not provide Services to the personswho are residents of jurisdictions that are identified by the FATF as high riskand non-cooperative jurisdictions having strategic AML/CFT deficiencies, namelyNorth Korea and Iran.

15. The Company doesn’t provide services to citizens andresidents of USA.

16. The Company reserve the rights to refuse performing theoperations that from Company’s point of view are considered to be a suspicious,using of preventive measures (such as blocking or closing of a Customer’saccount) is not the reason for civil liability of the Company for failure tofulfill obligations to the Customer.

17. The Company is not obliged to inform the Customer orother persons about the measures taken to fulfill the AML/CFT legislation. theCompany is not obliged to inform Customers or other persons about anysuspicions, about the reasons of refuse of execution of a Customer’s order, toopen the Account, need for providing Customer’s documents, etc.

18. This Anti-money laundering and Know your customerpolicy is an integral part of the Customer agreement, located on the Websites.Non-compliance with this policy may result in termination of the Customeragreement, based on the Company sole discretion.

DOCUMENTS TYPES

Proof of Identity (POI) – Anygovernment issued identity.
Proof of Residency (POR) –Utility bill, Bank statement or any Government issued document.showing the name and address of the customer dated withinthe last 3 month of account opening date.
Deceleration of Deposit (DOD) –Declaration of deposit, in some cases based on The Company sole discretion, wewill issue this document showing the Customer acknowledging the depositdetails, this document must be signed by the Customer.Policies and Agreements Customer must agree bychecking the boxes, to ALL Agreements and Policies on the websites, prior toestablish any financial relationship with the Company.
Source of Funds (SOF) Acceptable Source of Funds are:
Savings Account – A bank statements from the last 6months showing the funds in your bank account.
Sale of Assets – A copy of your bank statementshowing the money being received from the solicitor following the sale.
Salary Income – A bank statements for the last 6months showing an accumulation of funds in your bank account.
Company Shares – A copy of the share release scheduleand a copy of your bank statement showing the money being received from theshares.
Pension – A copy of your pension release documentand a copy of your bank statement showing the money being received from thepension company.
Inheritance – A copy of your bank statement showingthe money being received from the solicitor/executor’s bank account.
Company Dividends – A copy of your dividendcertificate, a copy of the company’s accounts and a copy of your bank statementshowing the money being received from the Company.

VERIFICATION LEVELS

VERIFICATION LEVELS ARE SEGMENTED BY TRANSACTIONS AMOUNT
Tier 1: up to 15,000 EUR
Tier 2: 15,000 EUR or higher
*Crypto purchases using Cards are limited to 25k EUR

Tier 1
One of the following is required:
1- Passport & Utility Bill
2- ID Card Front & ID Card Back & Utility Bill
3- Driving License Front & Driving License Back & Utility Bill

Tier 2
One of the following is required:
1- Passport & Utility Bill & Selfie & Source Of Funds
2- ID Card Front & ID Card Back & Utility Bill & Selfie & Source Of Funds
3- Driving License Front & Driving License Back & Utility Bill & Selfie & Source Of Funds
4- Bank Statement & Passport & Selfie & Source Of Funds
5- ID Card Front & ID Card Back & Bank Statement & Selfie & Source Of Funds
6- Driving License Front & Driving License Back & Bank Statement & Selfie & Source Of Funds.
KYC documents will be verified within 24hours of uploading, and email will be sent once the account is Verified.

CORPORATE AND INSTITUTIONS
This policy is applied for the Corporate and Institutional Customers only (hereinafter “Business”), the Company allowing to apply to Account Tier 3 for Business in this category, however they must go through the obligatory enhanced verification process.
The Company reserves its right to refuse the Business in provision of services if during the process of verification, it is discovered that the Customer do not correspond with the Company KYC requirements. The Company also have a right to terminate the existing relationships with the Business in any time in case if the Business considered to be violating the Company KYC requirements. Upon The Company request of any additional documents and/or information those should be provided by the Business, shell the Business refuse to provide such documents or information this also may lead to the Company refuse or termination of provision of all services.
Verification measures may vary on case by case basis, and including but not limited to, third-party software checks, due diligence, any or all public information about the Business history.

DUE DILIGENCE

SIMPLIFIED DUE DILIGENCE

·     Obtaining fewer elements of Customer’s identification data, seeking less robustverification of the customer identity.

·       Notcollecting specific information or carrying out specific measures to understandthe purpose and intended nature of the business relationship, inferring thepurpose and nature from the type of transactions or business relationshipestablished.

·      Verifying the identity of the customer and the beneficial owner after theestablishment of the business relationship (e.g. if transaction values riseabove a defined monetary threshold).

·       Reducingthe frequency of customer identification updates in case of businessrelationship.

·       Reducingthe degree and extent of on- going monitoring and scrutiny of transactions,based on a reasonable monetary threshold.

ENHANCED DUE DILIGENCE
Customer’s Risk-Level will be consideredhigher should in any of the following cases occur:

·       TheCustomer is a person associated with a PEP.

·       TheCustomer is a PEP or a local PEP.

·       TheCustomer is suspected to be or to have been linked with a financial offence orother suspicious activities.

·       TheCustomer is a non-resident individual, whose place of residence or activitiesis in a country, which is listed in the list of risk countries.

·       Whensuspicion arises regarding the truthfulness of the provided data and/or ofauthenticity of the identification documents of the Customer or its BeneficialOwners.·       Whensuspicion arises of a situation with higher risk of Money-Laundering andterrorists financing.

·       TheCustomer is a Cooperate or Institution, using a nominee shareholders or sharesin bearer form.Obtaining and corroborating additionalidentifying information from a wider variety or more robust sources and usingthe information to inform the individual customer risk profiling. Carrying outadditional searches (e.g. verifiable adverse internet searches) to betterinform the individual customer risk profiling. Where appropriate, undertakingfurther verification procedures on the customer or beneficial owner to betterunderstand the risk that the customer or beneficial owner may be involved incriminal activity. Verifying the source of funds or wealth involved in thetransaction or business relationship to be satisfied that they do notconstitute the proceeds from crime. Evaluating the information provided withregards to the destination of funds and the reasons for transaction. Seekingand verifying additional information from the customer about the purpose andintended nature of the transaction or the business relationship. Steps toidentify customers and check whether they are who they
say they are. Requestand obtain the following:

NEUTRAL PERSON
·       FullName.

·       Date ofBirth.

·       PhoneNumber.

·      Transaction exceeds 15,000 EUR. Customer will have to verify identity withadditional Liveness check or Selfie.

·      Transaction exceeds 100,000 EUR. Customer will have to verify the Source Of Funds (SOF).

LEGAL PERSON

·       Fullname or business name of the legal person.

·      Identifying all beneficial owners, where applicable, and taking reasonablemeasures to verify their identity.

·      Obtaining information on the purpose and intended nature of the businessrelationship.

·       Registrycode or registration number and the date of registration.

·       Names ofthe director, members of the management board or other body replacing themanagement board, and their authorization in representing the legal person.

·       Detailsof the telecommunications of the legal person.

·       Detaileddescription of business processes.

·       Registrycard of the relevant register. Depending on the results of due diligence, thelist of documents may be changed by discretion of Vikingbond OU.

ONGOING MONITORING

Ongoing monitoring on arisk basis means the scrutiny of transactions to determine whether thosetransactions are consistent with the MVTS provider’s information about thecustomer and the nature and purpose of the business relationship, whereverappropriate. Monitoring also involves identifying changes to the customerprofile (for example, their behavior, use of products and the amount of moneyinvolved), and keeping it up to date, which may require the application ofenhanced CDD measures. Monitoring transactions is an essential component inidentifying transactions that are potentially suspicious. Transactions that donot fit the behavior expected from a customer profile, or that deviate from theusual pattern of transactions, may be potentially suspicious.

ANTI-FRAUD

Vikingbond OÜ using themost advanced tools to evaluate of financial transactions on the Internet forsuspicion from the point of fraud and offering recommendations for theirfurther processing. All Bank Cards transactions go thru 3D Security andstarting from Aug. 2020 working on Pre-Authorization that will only be Clearedafter 12-hours. Vikingbond OÜ is guided by thefollowing standards:

– Establishing and maintaining a risk-basedApproach towards assessing and managing the money laundering and terroristfinancing risks to the company.

– Establishing and maintaining risk-basedcustomer due diligence, identification, verification and know your customerprocedures, including enhanced due diligence.

– Establishingand maintaining risk-based systems and procedures to monitor on-going customeractivity.

– Procedures forreporting suspicious activity internally and to the relevant law enforcementauthorities as appropriate.

– Maintenance ofappropriate records for the minimum prescribed periods.– Training andawareness for all relevant employees. 

REPORTING

Vikingbond OÜ is obliged to report to the FinancialIntelligence Unit in the event of suspicion of money laundering or terroristfinancing. 

INDEPENDENT AUDIT

Vikingbond OÜ plans to contract with independentaudit service to test the AML/CFT program with a view to establishing theeffectiveness of its AML/CFT policies and processes and the quality of its riskmanagement across its operations, departments, branches and subsidiaries, bothdomestically and, where relevant, abroad.

COMPLIANCEOFFICER REQUIREMENTS

Responsibilityfor the consistency and effectiveness of AML/CFT controls is clearly allocatedto an individual of sufficient seniority within the MVTS provider to signal theimportance of ML/TF risk.
management and compliance, and that ML/TF issues are brought to seniormanagement’s attention.
This includes the appointment of a skilled compliance officer at managementlevel.

AMLEMPLOYEES REQUIREMENTS

All Employees are expected to be fully aware of the Vikingbond OÜ anti-money laundering policies and procedures.To ensure the continued adherence to Vikingbond OÜ anti-money laundering policies and procedures, all Employees are required to reconfirm their awareness of the contents of this