Anti-Money Laundering (AML) Policy

1.1 Policy Statement

The Bitcoin Corporation LTD is committed to preventing the use of our platform and token offerings for money laundering, terrorist financing, and other illicit activities. Our AML program is designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

1.2 Regulatory Framework

Our AML program complies with:

• Bank Secrecy Act (BSA): 31 U.S.C. 5311 et seq.
• USA PATRIOT Act: Sections 314(a), 314(b), and 326
• FinCEN Regulations: 31 CFR Chapter X
• OFAC Sanctions: Office of Foreign Assets Control requirements
• FATF Guidelines: Financial Action Task Force recommendations
• State Money Transmission Laws: Where applicable

1.3 Program Components

Our comprehensive AML program includes:

2.1 Risk-Based Assessment

All investors undergo risk assessment based on multiple factors to determine the appropriate level of due diligence required:

• Low Risk: Domestic investors with verified identity and clean background
• Medium Risk: Foreign investors from low-risk jurisdictions
• High Risk: PEPs, high-risk jurisdictions, or complex ownership structures

2.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required for high-risk customers, including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk or non-cooperative jurisdictions
• Customers with complex ownership or control structures
• Customers conducting large or frequent transactions
• Customers in high-risk business sectors

2.3 Beneficial Ownership Identification

For corporate and institutional investors, we identify and verify beneficial owners who directly or indirectly own 25% or more of the entity, including:

• Individual ownership percentages and control structures
• Senior managing officials for entities without qualifying beneficial owners
• Trust beneficiaries and settlement arrangements
• Ultimate controlling parties in complex structures

3.1 Screening Lists

All customers and transactions are screened against comprehensive sanctions lists:

3.2 Screening Process

Sanctions screening occurs at multiple points:

• Onboarding: Initial customer screening during KYC process
• Transaction Processing: Real-time screening of all transactions
• Periodic Review: Regular rescreening of existing customers
• List Updates: Immediate screening when sanctions lists are updated

3.3 Match Resolution

When potential sanctions matches are identified, our compliance team follows a structured resolution process:

• Immediate transaction suspension pending review
• Manual review of customer information and match quality
• False positive determination or match confirmation
• Account blocking and regulatory reporting for true matches
• Documentation of all resolution decisions

4.1 Monitoring Systems

Automated transaction monitoring systems analyze all customer activities for potentially suspicious patterns:

• Large cash transactions exceeding reporting thresholds
• Structuring activities to avoid reporting requirements
• Unusual transaction patterns inconsistent with customer profile
• Rapid movement of funds through multiple accounts
• Transactions with high-risk jurisdictions or entities
• Transactions that may indicate trade-based money laundering

4.2 Alert Generation and Review

The monitoring system generates alerts based on:

4.3 Investigation Process

When alerts are generated, our compliance team conducts thorough investigations:

• Review of customer transaction history and profile
• Analysis of transaction purpose and business rationale
• Enhanced due diligence on counterparties
• Documentation of findings and conclusions
• Escalation to senior management for significant concerns

5.1 SAR Filing Requirements

Suspicious Activity Reports (SARs) are filed with FinCEN when transactions or patterns meet reporting criteria:

• Transactions of $5,000+ involving known or suspected criminal activity
• Transactions designed to evade reporting requirements
• Transactions with no apparent lawful purpose
• Transactions involving suspected terrorist financing
• Computer intrusion activities

5.2 Filing Timeline and Process

SAR filings follow strict regulatory deadlines:

• Initial Detection: Suspicious activity identified
• Investigation Period: 30 days maximum for investigation
• Filing Deadline: 30 days from completion of investigation
• Supporting Documentation: Maintained for 5 years minimum
• Continuing Activity: Additional SARs filed every 90 days if ongoing

5.3 Confidentiality Requirements

SAR filings and related information are strictly confidential:

• No disclosure to customers or unauthorized personnel
• Limited access on need-to-know basis
• Secure storage of SAR-related documentation
• Protection from discovery in civil litigation

6.1 Required Records

The following records are maintained in accordance with regulatory requirements:

6.2 Record Accessibility

All records are maintained in a format that ensures:

• Immediate availability for regulatory examination
• Searchable and sortable formats
• Complete audit trail maintenance
• Protection against unauthorized access or modification

7.1 Staff Training Program

All personnel receive comprehensive AML training covering:

• AML laws and regulations
• Company policies and procedures
• Red flag identification
• Sanctions screening procedures
• Suspicious activity detection and reporting
• Customer due diligence requirements

7.2 Training Schedule

• New Employee Training: Within 30 days of hire
• Annual Refresher Training: All staff annually
• Specialized Training: Role-specific training for compliance staff
• Update Training: When regulations or procedures change

7.3 Testing and Auditing

The AML program is subject to regular testing and independent auditing:

• Annual independent AML audit by qualified external firm
• Quarterly internal compliance testing
• Monthly transaction monitoring effectiveness reviews
• Annual board reporting on AML program effectiveness