Date of Last Revision: May 3, 2017


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LLC Bitwallet (I/N 406139334)



Anti-Money Laundering Policy


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Content

  1. Introduction 3

  2. Definition of terms 3

  3. Internal control system 5

  4. Internal policy and procedures 6

  5. Employees responsible for control 6

  6. Risk based approach 7

  7. Control mechanisms 7

    1. Customer Identification 8

    2. Limits and restrictions 8

    3. Monitoring System 11

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    4. Record Keeping 11

  1. Reporting 12

  2. Stuff selection and training 13

  3. Approve of new products and services 13


    1. Introduction


      LLC Bitwallet (hereinafter - the organization) is a payment service provider which provides customers with pre-payment cards, electronic wallet services and receives payments for mobile operators (hereinafter - product). The goal of the company is to offer fast, flexible and secure services on the one hand and on the other hand to carry out activities in full compliance with the requirements of business ethics and Georgian legislation.

      For this purpose, organization has developed a policy of "Anti-Money Laundering" (hereinafter - the policy), which is based on the “law of Georgia on facilitating the prevention of illicit income

      legalization” “Regulation on Receiving, Systemizing and Processing the Information by Payment Service Provider and Forwarding to the Financial Monitoring Service of Georgia”, the Financial Action Task Force (FATF) recommendations and the fourth European Union (EU) 2015/849 Directive on legal and regulatory requirements.


      The policy aims to define an appropriate control system for the fight against money laundering and terrorism financing.


      Policies are approved by the organization's board of directors and are subject to annual revision.


    2. Definition of terms


      Money laundering - the legalization of illicit income (acquisition, use, transfer or other action), as well as hidding or concealment of its true origin, owner or possessor and / or ownership rights and / or attempt to commit such an act;


      Terrorism financing - any transaction, completed directly or indirectly, by any person, in any manner illegal and intentionally (regardless of amount of money) aimed at obtaining, or collecting funds that is aimed to use for financing terrorism and/or acts of terrorism. In some cases it can be extended to legally obtained sources as well.

      Illicit income - illegal and / or unjustified wealth of a person;


      Property - any items (both movable and immovable) and non-material property which can be owned, utilized and managed by individual and/or legal entity;


      Identification - obtaining information about customer that allows to trace the person and gives the ability to distinguish him/her from other persons.


      Customer – an individual that addresses the organization for the purpose of obtaining services and / or establishing business relations based on its activities;


      Business relationships - a contract based relationship with the customer who is directly related to receiving recurring a services. According to this policy, the registration of the e-wallet is considered as a business relationship.


      Suspicious transaction – a transaction (irrespective of the amount and type of the transaction) with respect to which there are reasonable grounds for suspecting that the transaction has been entered into or conducted for the purpose of illicit income legalization and / or that property (including funds), based on which the transaction has been entered into or conducted, has been obtained or originated from Criminal activities, and / or transaction has been entered into or conducted for financing terrorism (a party to the transaction or the origin of the transaction amount is suspicious, or there are other grounds for which the transaction maybe considered suspicious), or that any party to the transaction is included in the list of terrorists or persons supporting terrorism and/or maybe related to them, and/or the amount involved in the transaction maybe related to or used for terrorism, terrorist acts, or by terrorists or terrorist organizations or by entities financing terrorism, or that the legal or actual address or place of residence of a party to the transaction is within a non-cooperative area or that the transaction amount is transferred to or from non-cooperative area;

      An unusual transaction – complex, unusually large transaction (operation) and / or part of a transaction (operation), which have no explicit economic (commercial) content or an explicit legitimate aim and / or which are not in conformity with the normal activity of the person involved in the transaction;


      Set of transactions - According to this policy, the sum of the transactions performed in a certain period of time in favor of one person or by one person when total amount exceeds 30,000 GEL or its equivalent in another currency, and there is a reasonable doubt that the partitioning of the transaction was done intentionally to avoid reporting. An analysis made by responsible person is the base of substantiation of doubt.


    3. Internal control system


      To prevent money laundering and terrorism funding, the organization provides an effective internal control system, which consists of the following components:


      • Internal policy and procedures

      • Employees responsible for control


      • Risk based approach

      • Control mechanisms

      • Record keeping

      • Reporting

      • Staff selection and training


    4. Internal policy and procedures


      This policy is the basis of internal control, which defines the general principles for prevention of money laundering and terrorism financing, responsibilities and control mechanisms. In addition to this policy, additional internal procedures define detailed control mechanisms.


      The "Know Your Customer" procedure is an additional document of this Policy, which provides a detailed description of the identification, verification and ongoing monitoring process.


      The procedure defines the risk criteria for the organization's products and customers and the risk- appropriate control mechanisms for identification and verification of customers.


      This policy, as well as additional procedures is accessible for all employees.


    5. Staff Responsibilities


      On the basis of a properly signed decision the organization shall appoint the employee responsible for control of money laundering (hereinafter - the responsible employee) whose detailed job description is determined by a separate document.


      The responsible employee is responsible to set and maintain the internal control system defined by this policy. In order to effectively perform this function, the organization must provide all necessary resources, including appropriate technical and IT tools, for secure storage of information, documentation and etc.


      Along with the responsible employee, the efficiency of the money laundering control system is the responsibility of the organization's board of directors. Also, implementing separate tools for controls


      is responsibility of those employees who are directly involved in establishing business relations with the customers.


    6. Risk based approach


      The basis for anti-money laundering control in the organization is a risk-based approach, according to which the organization classifies its products and customers as low and medium risk categories. The basis for determining the organization's anti-money laundering and terrorist financing risks is the identification and assessment of relevant risk factors.

      The purpose of identification and assessment of risk factors is to determine medium and high-risk category products and adequate control mechanisms for customers, on the basis of which it will be possible to reduce and manage risks of money laundering and terrorism financing.


      Detailed process of defining, evaluating and assigning risk factors is described in the "Know Your Customer" procedure of the organization.


    7. Control mechanisms

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Limits and Restrictions

Product of law risk (non-reloadable identified

card)

Product of medium risk (Identified card)


Monetary


Max. Limit


500 ₾/GEL


1 000 ₾/GEL


Limit of payment transaction


500 ₾/GEL


1 000 ₾/GEL

Limit of deposit via payment devices


Not avaliable


According to the max. limit which is allowed for the card

Limit of deposit via Georgian cards


Not available


According to the max. limit which is allowed for the card

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Limit of deposit via foreign cards


Not avaliable


According to the max. limit which is allowed for the card

Limit of money totally used in 1

day


500 ₾/GEL


1 000 ₾/GEL


Quantitative

Number of cards given to one person


5


2


Total number of payment transactions


unlimited


unlimited


Geografical


international


international


Functional


Deposite of money


Not avaliable


Avaliable via: cash, payment devices, card, by transaction from wallet to wallet


Money encashment


Avaliable: ATM


Avaliable: ATM


Electronic wallet


Avaliable


Avaliable


Validity period


6 Months


12-24 Months


    1. Monitoring System

    2. Record keeping

      • Customer identification data, documents and/or copies of these documents.

      • If the customer is identified via electronic means of identification (via data base of Public Service Development Agency) – printed version of received identification data;

      • Each information requested from the data base of Public Service Development Agency – the version of report;

      • Information about transaction (operation) – original (if any) as well as electronic version;

      • Reports sent to Financial Monitoring Services of Georgia – printed as well as electronic version. Organization will ensure that above listed records, documents and evidences of transactions will be preserved during six years since carrying out the transaction.

An important control mechanism of the organization is the monitoring system based on information technologies, which allows to detect and identify the unusual and / or suspicious transaction according to the typologies and characteristics of money laundering and terrorism financing. Monitoring system takes into account risks typical for customer and product and, also, is aimed to detect the set of transactions.

Organization also uses monitoring system based on informational technologies to check international financial sanctions and embargos used against individuals, subjects and countries.


Organization records and keeps the following information and documentation:


8. Reporting


Monitoring of the transactions performed by customers and reporting them to the Financial Monitoring Service of Georgia (hereinafter - FMSG) is the important part of organization’s internal control system.


The following operations shall be reported to FMSG:



enrolled in operation, might be connected to or used for terrorism, act of terrorism or used by terrorists, terrorist organization or by person, who finances terrorism – at the day of receiving the corresponding information.


Doubtful, unusual or/and significant cases shall be investigated immediately by the responsible employee. If there is a reasonable doubt towards origination of funds involved in operation or business relationship or towards reputation of the party, the reports about such suspicious transactions shall be sent to FMSG immediately. Detailed instructions about indicators of identification of money laundering and financing of terrorism is defined by the procedure “know your customer”.


  1. Staff selection and training


    Taking into account the fact, that money laundering and financing of terrorism is often assisted by employees of financial institutions, the organization will use intensified measures of identification of candidates in the recruitment process. In this process an important attention is paid to reputation, qualification and honesty of a candidate.

    Each employee of the organization, who is taking part in the process of establishing a business relationship with the customer shall be trained personally within one month from the moment of hiring and retrained annually. The responsible employee of the organization shall participate in professional training at least annually. The training shall have an appropriate rank to raise an awareness of employee towards obligations defined by corresponding regulatory rules.


  2. Approval of new products and services


If the organization designes a new product or services for customer or significantly changes existing products or services, before implementation of such changes, risk assessment of money laundering and financing of terrorism shall be carried out by the organization. The responsible employee takes part in the process of risk assessment, whose recommendations shall be taken into account before the final approval of the design of product/service.


Risk evaluation of money laundering and financing of terrorism is also mandatory if the organization considers the segmentation of services or use of intermediary organizations in the different phases of the organization’s processes.