AML Policy
Last Updated: March 26, 2026
SECTION A — INTRODUCTION
1. Introduction & Purpose
1.1 Bit1 ("Bit1", "we", "us", "our") is committed to preventing money laundering, terrorist financing, and other financial crimes across our digital asset trading platform and related services.
1.2 This Anti-Money Laundering Policy ("AML Policy") outlines our comprehensive framework for combating financial crimes, including our obligations under applicable anti-money laundering and counter-terrorism financing ("AML/CFT") laws and regulations.
1.3 Our Commitment: Bit1 maintains a zero-tolerance approach to money laundering, terrorist financing, sanctions violations, and any other illicit financial activities. We are dedicated to maintaining the integrity of the global financial system.
1.4 Scope: This policy applies to all users of our platform, all transactions processed through our services, and all employees, contractors, and agents acting on behalf of Bit1.
1.5 Compliance Culture: Every member of the Bit1 team is responsible for upholding the highest standards of compliance and reporting any suspicious activity or potential violations immediately.
SECTION B — REGULATORY FRAMEWORK
2. Regulatory Framework
2.1 International Standards: Bit1's AML program is designed in accordance with international standards, including the Financial Action Task Force ("FATF") recommendations and guidelines issued by relevant international bodies.
2.2 Risk-Based Approach: Our AML framework employs a risk-based approach, allocating resources and implementing controls proportionate to identified money laundering and terrorism financing risks.
2.3 Continuous Monitoring: We maintain ongoing compliance with evolving regulatory requirements and industry best practices, regularly updating our policies and procedures to reflect current standards.
2.4 Global Compliance: As a platform serving users across multiple jurisdictions, we maintain compliance standards that meet or exceed requirements in the markets where we operate.
2.5 Regulatory Cooperation: Bit1 cooperates fully with regulatory authorities, law enforcement agencies, and financial intelligence units in their efforts to combat financial crime.
SECTION C — CUSTOMER DUE DILIGENCE
3. Customer Due Diligence (CDD)
3.1 Standard Due Diligence: All customers undergo standard verification procedures including:
Government-issued identification document verification
Proof of address documentation
Biometric verification through selfie photograph
Identity matching and authentication checks
Basic risk assessment and screening
3.2 Simplified Due Diligence: For lower-risk customer profiles, we may apply simplified due diligence measures while maintaining appropriate oversight and monitoring.
3.3 Enhanced Due Diligence (EDD): Higher-risk customers are subject to enhanced due diligence procedures including:
Source of funds documentation and verification
Source of wealth documentation where applicable
Additional identity verification measures
Enhanced ongoing monitoring of account activity
Senior management approval for account opening
Periodic review of account activity and risk profile
3.4 Ongoing Monitoring: Customer due diligence is not a one-time process. We conduct ongoing monitoring of customer activity to:
Ensure transactions are consistent with customer profile and risk assessment
Identify unusual or suspicious transaction patterns
Update customer information and risk assessments as needed
Trigger additional due diligence when circumstances change
3.5 Record Keeping: All CDD documentation and assessments are maintained in accordance with regulatory requirements and our internal record retention policies.
SECTION D — KNOW YOUR CUSTOMER (KYC)
4. Know Your Customer (KYC)
4.1 Tiered Verification System: Bit1 employs a tiered KYC system with verification levels corresponding to transaction limits and platform access:
Verification Tier
Requirements
Benefits
Basic
Email verification
Limited access
Standard
Government ID + Proof of Address + Selfie
Full platform access
Enhanced
Additional documentation + Source of funds
Higher limits + Premium features
4.2 Verification Requirements:
Basic Tier:
Valid email address verification
Basic profile information
Limited trading and withdrawal capabilities
Standard Tier:
Government-issued photo identification
Proof of address (utility bill, bank statement, or government document)
Selfie photograph for biometric verification
Complete profile information including occupation
Enhanced Tier:
All Standard Tier requirements
Source of funds documentation
Additional identity verification measures
Enhanced background screening
Periodic review and re-verification
4.3 Re-verification Rights: Bit1 reserves the right to request additional documentation, re-verification, or enhanced due diligence at any time based on:
Changes in customer circumstances
Unusual transaction patterns
Regulatory requirements
Risk assessment updates
Suspicious activity detection
4.4 Information Updates: Customers are required to maintain current and accurate information. Material changes in circumstances must be reported promptly and may trigger re-verification procedures.
4.5 Verification Standards: All verification procedures meet or exceed international standards for customer identification and employ multiple authentication methods to ensure identity accuracy.
SECTION E — KNOW YOUR TRANSACTION (KYT)
5. Know Your Transaction (KYT)
5.1 Real-Time Monitoring: Bit1 employs advanced blockchain analytics and transaction monitoring systems to screen all deposits, withdrawals, and trading activities in real-time.
5.2 Automated Screening: Our KYT system automatically:
Analyzes blockchain transactions for suspicious patterns
Screens digital asset addresses against risk databases
Monitors transaction flows and clustering patterns
Flags unusual transaction behaviors for review
Generates risk scores for all transactions
5.3 Transaction Risk Assessment: Each transaction is evaluated based on multiple risk factors including:
Transaction amount and frequency
Geographic origins and destinations
Counterparty risk assessment
Historical transaction patterns
Blockchain analytics intelligence
5.4 Suspicious Pattern Detection: Our monitoring systems identify potentially suspicious activities including:
Structuring transactions to avoid reporting thresholds
Rapid movement of funds through multiple accounts
Transactions involving high-risk jurisdictions or entities
Unusual trading patterns inconsistent with customer profile
Potential mixing or tumbling activities
5.5 Investigation and Escalation: Flagged transactions undergo immediate review by our compliance team, with suspicious activities escalated for detailed investigation and potential reporting to relevant authorities.
5.6 Continuous Improvement: Our KYT systems are regularly updated with new intelligence, risk indicators, and analytical capabilities to maintain effectiveness against evolving money laundering techniques.
SECTION F — SUSPICIOUS ACTIVITY MONITORING & REPORTING
6. Suspicious Activity Monitoring & Reporting
6.1 Dedicated Compliance Team: Bit1 maintains a specialized compliance team responsible for reviewing flagged activities, conducting investigations, and making suspicious activity determinations.
6.2 Suspicious Activity Reports (SARs): When suspicious activity is identified, we file Suspicious Activity Reports with relevant authorities in accordance with applicable legal requirements and timeframes.
6.3 Account Actions: Bit1 may take immediate protective actions for accounts under investigation, including:
Freezing or suspending trading activities
Restricting deposits or withdrawals
Requiring additional verification or documentation
Closing accounts where appropriate
Reporting activities to law enforcement
6.4 Tipping Off Prohibition: In accordance with legal requirements, Bit1 does NOT notify customers when Suspicious Activity Reports have been filed regarding their accounts or transactions.
Important: Users will not be informed of SAR filings, ongoing investigations, or law enforcement inquiries. Any attempt to tip off subjects of investigations is strictly prohibited by law.
6.5 Investigation Standards: All suspicious activity investigations are conducted with:
Appropriate documentation and record keeping
Timely completion within regulatory timeframes
Senior management oversight and approval
Coordination with law enforcement when required
Protection of investigation confidentiality
6.6 Quality Assurance: Our suspicious activity reporting program includes regular quality reviews, staff training updates, and process improvements to ensure effectiveness and compliance.
SECTION G — SANCTIONS SCREENING
7. Sanctions Screening
7.1 Comprehensive Screening: All users, transactions, and digital asset addresses are screened against comprehensive sanctions lists including:
Office of Foreign Assets Control (OFAC) Specially Designated Nationals List
European Union Consolidated Sanctions List
UK Office of Financial Sanctions Implementation (OFSI) Consolidated List
United Nations Security Council Consolidated List
Other relevant national and international sanctions lists
7.2 Ongoing Monitoring: Sanctions screening is conducted:
At account opening and throughout the customer relationship
For every transaction and digital asset transfer
Through real-time monitoring of all platform activities
Via regular batch screening against updated lists
When sanctions lists are updated or modified
7.3 Politically Exposed Persons (PEP) Screening: We maintain enhanced screening procedures for Politically Exposed Persons, including:
Identification of PEPs and their associates
Enhanced due diligence requirements
Senior management approval for relationships
Ongoing monitoring of PEP accounts and activities
Regular review of PEP classifications and status
7.4 Ownership Screening: Entities that are 50% or more owned or controlled by sanctioned persons are subject to the same restrictions and prohibitions as the sanctioned individuals themselves.
7.5 Match Resolution: When potential sanctions matches are identified:
Immediate suspension of account access pending investigation
Detailed review of customer information and transaction history
Clear documentation of resolution decisions
Reporting to authorities when required by law
Permanent blocking of confirmed matches
7.6 List Updates: Sanctions lists are monitored continuously for updates, with new designations implemented immediately upon official publication.
SECTION H — RECORD KEEPING
8. Record Keeping
8.1 Customer Records: All customer due diligence and KYC records are retained for a minimum of five (5) years following account closure, including:
Identity verification documents and data
Proof of address documentation
Biometric verification records
Risk assessment documentation
Enhanced due diligence materials
Communications and correspondence
8.2 Transaction Records: Transaction data is maintained for a minimum of five (5) years, including:
Trading history and order details
Deposit and withdrawal records
Digital asset transfer documentation
Blockchain transaction hashes and confirmations
Fee calculations and payment records
KYT monitoring results and risk scores
8.3 Compliance Records: All compliance-related documentation is retained including:
Suspicious activity investigation files
SAR filings and supporting documentation
Sanctions screening results and decisions
Training records and certifications
Policy updates and implementation records
Regulatory correspondence and examinations
8.4 Regulatory Access: All records are maintained in formats readily accessible to regulatory authorities upon lawful request, with appropriate systems and procedures for:
Rapid retrieval and production of requested materials
Secure transmission of confidential information
Audit trail maintenance for all record access
Coordination with legal counsel when appropriate
8.5 Data Security: All retained records are protected through:
Encryption of sensitive data at rest and in transit
Access controls limiting personnel with business need
Regular security audits and vulnerability assessments
Backup and disaster recovery procedures
Secure disposal procedures for expired records
SECTION I — EMPLOYEE TRAINING
9. Employee Training
9.1 Comprehensive Training Program: All relevant Bit1 personnel receive regular AML/CFT training covering:
Legal and regulatory requirements
Company policies and procedures
Suspicious activity identification techniques
Customer due diligence best practices
Sanctions compliance requirements
Record keeping obligations
9.2 Specialized Training: Compliance team members and other key personnel receive enhanced training including:
Advanced investigation techniques
Regulatory examination preparation
Industry best practices and developments
Technology tools and analytical methods
Case studies and practical applications
9.3 Training Schedule: AML training is conducted:
Upon hire for all relevant personnel
Annually for all covered employees
When regulations or policies change significantly
Following regulatory guidance updates
Prior to system implementations or process changes
9.4 Training Documentation: All training activities are documented including:
Attendance records and completion certificates
Training content and materials provided
Assessment results and competency evaluations
Remedial training where necessary
Ongoing professional development activities
9.5 Competency Assessment: Regular evaluations ensure personnel maintain appropriate knowledge and skills through testing, practical exercises, and performance monitoring.
SECTION J — RISK ASSESSMENT
10. Risk Assessment
10.1 Comprehensive Risk Assessment: Bit1 conducts periodic comprehensive risk assessments evaluating money laundering and terrorism financing risks across:
Products and services offered
Customer types and demographics
Geographic exposure and operations
Transaction types and volumes
Technology systems and processes
Business partnerships and third-party relationships
10.2 Risk-Based Resource Allocation: Assessment results inform resource allocation decisions including:
Staffing levels for compliance functions
Technology investments and system enhancements
Enhanced due diligence triggers and procedures
Training priorities and specialized education
Monitoring system calibration and thresholds
10.3 Higher-Risk Area Controls: Areas identified as higher risk receive enhanced controls including:
Increased monitoring and surveillance
Additional due diligence requirements
Enhanced staff training and oversight
More frequent reviews and assessments
Specialized procedures and protocols
10.4 Risk Assessment Updates: Risk assessments are updated:
At least annually or more frequently as needed
When significant business changes occur
Following regulatory guidance or industry developments
After suspicious activity trends are identified
When new products or services are introduced
10.5 Documentation and Governance: All risk assessments include:
Clear methodology and analytical frameworks
Supporting data and evidence
Management review and approval
Action plans for addressing identified risks
Regular monitoring of mitigation effectiveness
SECTION K — COOPERATION WITH AUTHORITIES
11. Cooperation with Authorities
11.1 Full Cooperation: Bit1 cooperates fully and promptly with all law enforcement agencies, regulatory authorities, and financial intelligence units in their efforts to combat financial crime.
11.2 Lawful Requests: We respond expeditiously to all lawful requests for information including:
Subpoenas and court orders
Regulatory examination requests
Law enforcement investigations
Administrative summons and information requests
International cooperation requests
11.3 Information Sharing: Subject to applicable legal requirements, we share relevant information with:
Financial intelligence units for suspicious activity reporting
Law enforcement for criminal investigations
Regulatory authorities for compliance examinations
International partners for cross-border investigations
Industry groups for threat intelligence sharing
11.4 Response Procedures: Our authority cooperation procedures ensure:
Immediate notification to senior management
Coordination with legal counsel when appropriate
Rapid retrieval and production of requested materials
Secure transmission of confidential information
Detailed documentation of all interactions
11.5 Compliance Contact: For all compliance-related inquiries, regulatory matters, and law enforcement cooperation:
Contact: [email protected]
11.6 Emergency Procedures: For urgent law enforcement matters requiring immediate attention, we maintain 24/7 escalation procedures to ensure rapid response capabilities.
SECTION L — POLICY GOVERNANCE
12. Policy Updates
12.1 Regular Review: This AML Policy is reviewed and updated regularly to ensure continued effectiveness and compliance with evolving legal and regulatory requirements.
12.2 Update Triggers: Policy updates may be prompted by:
Changes in applicable laws and regulations
Regulatory guidance or industry best practice updates
Internal risk assessment findings
Examination findings or regulatory feedback
Significant business or operational changes
Emerging threats or typologies
12.3 Approval Process: All policy updates require:
Senior management review and approval
Legal and compliance assessment
Impact analysis and implementation planning
Employee notification and training
System updates where necessary
12.4 Change Communication: Material changes to this policy will be:
Posted to this page with clear effective dates
Communicated to all relevant personnel
Reflected in training materials and procedures
Documented with change rationales and approvals
12.5 Version Control: We maintain comprehensive records of all policy versions, changes, and implementation dates for regulatory and audit purposes.
By using Bit1's services, you acknowledge that you have read, understood, and agree to comply with this Anti-Money Laundering Policy. Violations of AML requirements may result in account suspension, termination, and reporting to relevant authorities.
Last updated
Was this helpful?