ANTI-MONEY LAUNDERING POLICY AND PROCEDURES of BITIN
Last review date: 28.2.2018

POLICY STATEMENT
These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by BITIN in compliance with the Money Laundering Regulations 2007 (MLR). The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:
The identities of all new and existing clients will be verified to a reasonable level of certaintyAny suspicious activity will be reported, and all AML activities recordedWe have a person that acts as the Money Laundering Reporting Officer (MLRO) to coordinate the AML policies and procedures of the business.All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.

ANTI-MONEY LAUNDERING PROCEDURES FOR of BITIN
CUSTOMER DUE DILIGENCE
The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty. This will include all clients in relation
ip with the business .
The business will actively not accept high-risk clients that are identified as with known higher levels of corruption, organised crime or drug production/distribution, criminalit
or terrorist activity.
No action need be taken if there is no cause for suspicion

RECORD-KEEPING
Records of all identity checks will be maintained for up to 7 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data or information held in evidence of customer identity are kept up to date.All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.