BTCBOX Co.,Ltd.(hereinafter referred to as we/us), are positioning countermeasures anti money laundering & terrorism financing (hereinafter referred to as “money laundering / terrorist fund provisioning measures”) as one of the most important management issues, we’re taking measures as below, and develop by the whole company.
1. Organizational structure
- Our board of directors recognizes and understands the importance of money laundering & terrorist fund provisioning measures, and tackles these measures actively.
- Decide responsible person & controlling department for money laundering and terrorism financing countermeasure, construct a unified management system, and coordinates across the organization under the cooperation of related departments.
- Clarify roles and responsibilities with regard to money laundering and terrorism fund supply countermeasures, and develop an internal posture that can respond timely and accurately.
2. Countermeasure anti money laundering and terrorism financing based on risk-based approach
- Based on the concept of risk-based approach, we identify and evaluate the risks related to money laundering and terrorist financing which we are faced by ourselves, effectively utilize IT system and various data, take measures to reduce risk.
- Regarding the risk identification / evaluation and reduction measures, periodically verify its effectiveness and review it as necessary.
- implement appropriate transaction monitoring and filtering to improve the detection, monitoring and analysis of suspicious customers and transactions.
3. Transaction confirmation and customer management measures
- In addition to carrying out transaction-time confirmation based on related laws and regulations, we are making appropriate customer management and strive to eliminate business relationships with inappropriate customers including anti-social forces.
4. Customer management policy
- Upon confirming transactions with customers, we take appropriate measures in accordance with the concept of risk-based approach, such as implementing measures in line with customer attributes such as public status.
In addition, record the results of periodic survey & analyzes of customer transaction, and utilize them to review countermeasures.
5. Reporting suspicious transaction
- We developed an internal system that can respond suspicious transaction reporting timely and accurately.
- Report suspected transactions through abnormality detection at transaction time, transaction monitoring, customer filtering, report within the company etc.
6. Economic sanctions and asset freezing
- We will properly implement measures such as eliminating business relationships or freezing assets with persons subject to sanction based on domestic and overseas controls etc..
7. Training for executives and employees
- We’re deepening executives and employees’ knowledge and understanding of countermeasures against money laundering and terrorism financing through guidance and training, endeavor to have expertise and conformity according to the role.
8. Internal audit
- The internal audit division regularly conducts verification from an independent standpoint on whether the sales department and the administrative department are functioning properly, whether there is space for further advancement.
- From the independent standpoint, the internal auditing department periodically reviews the effectiveness of policies, procedures, plans, etc. concerning the company-wide money laundering and terrorism financing provision; recommends and points out the need to revise policies, procedures, plans, etc. and improve the measures as necessary.
9. Continuous improvement
- We regularly inspect the effectiveness of our system related to the provision of money laundering and terrorism financing, and strive to continuously improve it based on the results.