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Anti-Money Laundering

Last update: July, 2017

Courts and jurisdictions are divided on whether or not digital and virtual currencies are a currency. Accordingly, digital and virtual currencies may or may not be “money” and, therefore, not subject to anti-money laundering statutes. We have developed and You agree to abide by Our anti-money laundering policy which is designed to meet strict standards, including the existence of systems and controls to mitigate the risk presented to any person who accesses or uses the Service. This includes, but is not limited to:

     • Establishing robust internal policies, procedures and controls that strive to combat any attempted use of BOA
          for illegal or illicit purposes and to ensure our customers basic protections under consumer protection laws;
     • Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
     • Filing Suspicious Activity Reports (“SARs”);
     • Filing Currency Transaction Reports (“CTRs”);
     • Maintaining comprehensive records of orders and other transfers;
     • Appointing a Chief Compliance Officer who will be responsible for the implementation and oversight of our BSA/AML Program;
     • Executing Know Your Customer (“KYC”) procedures on all customers;
     • Performing regular, independent audits of our BSA/AML Program;
     • Following record retention requirements; and
     • Implementing a formal and ongoing compliance training program for all new and existing employees.

Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner, and prevent fraud. In accordance with this, in order to open an Account, Your identity must be verified, authenticated, and checked against government watch-lists, including the Office of Foreign Assets Control (“OFAC”). If You are an individual, prior to opening an account, We will collect, verify and authenticate the following information:

     • Email address;
     • Mobile phone number;
     • Full legal name;
     • Social Security Number (“SSN”) or any comparable identification issued by government;
     • Date of birth (“DOB”);
     • Proof of identity (e.g., driver’s license, passport or government-issued ID);
     • Home address (not a mailing address or P.O. Box); and
     • Additional information or documentation at the discretion of our Compliance Team.
     • Non-US Customers will be required to provide proof of address (e.g., electric, gas or water bill).

If You are an institutional customer, We will collect, verify and authenticate the following information:

     • Legal name;
     • Employer Identification Number (“EIN”) or any comparable identification number issued by government;
     • Full legal name (of all account signatories and beneficial owners);
     • Email address (of all account signatories);
     • Mobile phone number (of all account signatories);
     • Address (principal place of business and/or other physical location);
     • Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued
          business license, trust instrument or other comparable legal documents as applicable);
     • Contract information of owners/principals/executive management (as applicable);
     • Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
     • Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).
     • If your institution successfully meets and completes our CIP requirements and neither it nor any of its owners, principals, executive, or managers
          appear on OFAC or any other governmental watchlist, we will provide you with account opening agreements electronically.

We also file required reports (i.e. Suspicious Activity Reports) if we know, suspect or have reason to suspect suspicious activities have occurred. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. Our compliance department monitors transaction to help identify unusual patterns of customer activity. In addition, all currency transactions over a determined amount are required to be reported to the US government (i.e. FinCEN). Our compliance department maintains records and supporting documentation of all reports filed.

All records are retained for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

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