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AML Policy
Bitreadypay is dedicated to operating with the highest levels of transparency, and regulatory compliance in delivering its on-ramp and off-ramp solutions. This AML Policy sets out the controls, processes, and safeguards adopted to prevent the platform from being exploited for money laundering, terrorist financing, or any other unlawful activities.
This policy applies across all areas of the business and operational activities.
1. Customer Due Diligence (CDD)
1.1 Customer Identification
Bitreadypay ensures that the identity of every customer is established and confirmed using trustworthy and independent sources. This process includes the collection and verification of official identity documents, address confirmation, and, where relevant, corporate registration and ownership information. We utilize automated liveness detection to prevent identity fraud and synthetic identity use.
1.2 Risk-Based Controls
Bitreadypay evaluates the potential risk associated with each customer and transaction by considering factors such as geographic exposure, nature of business, and transactional behavior. Customers classified as higher risk are subject to enhanced due diligence (EDD) procedures and additional monitoring measures.
2. Know Your Customer (KYC)
2.1 Data Collection
During onboarding, Bitreadypay gathers essential customer details, including full name, date of birth, contact information, and, for corporate clients, beneficial ownership data.
2.2 Continuous Review
Customer accounts and transactional activity are continuously reviewed to identify irregular patterns or suspicious behavior. Customer risk profiles are updated periodically to reflect changes in activity, risk level, or regulatory requirements.
3. Transaction Monitoring
3.1 Monitoring Systems
Bitreadypay operates automated transaction monitoring tools designed to identify unusual, complex, or high-risk activity patterns. Our monitoring extends to “On-Chain” analytics, screening wallet addresses for associations with sanctioned entities, mixers, or illicit protocols.
3.2 Reporting of Suspicious Activity
Any transaction or behavior that raises suspicion is promptly investigated and, where necessary, reported to the relevant regulatory and law enforcement authorities in compliance with applicable legal obligations.
5. Blockchain Compliance & The Travel Rule
As a Virtual Asset Service Provider (VASP), Bitreadypay complies with the FATF “Travel Rule.” We ensure that required originator and beneficiary information is securely transmitted for cross-border virtual asset transfers exceeding the applicable regulatory threshold.
6. Record Retention
Bitreadypay maintains detailed and accurate records relating to customer identification, transaction activity, and regulatory reporting. All records are securely stored and retained as required under applicable laws.
6. Staff Training and Awareness
6.1 Training Initiatives
Regular training programs are delivered to ensure that employees understand AML regulations, recognize potential warning signs (red flags), and follow established internal procedures.
6.2 Internal Reporting Duties
Employees are required to promptly report any suspicious transactions, behaviors, or compliance concerns to the appointed Compliance Officer.
7. Risk Identification and Mitigation
Bitreadypay carries out ongoing risk assessments to identify, analyze, and manage potential exposure to money laundering and terrorist financing risks arising from its services, customers, and operational model.
8. Compliance Oversight
A designated Compliance Officer is responsible for overseeing the implementation and effectiveness of this AML Policy. Key duties include monitoring compliance, performing internal reviews, ensuring regulatory alignment, and updating procedures as required.
9. Cooperation with Regulatory Authorities
Bitreadypay works closely with relevant regulatory bodies and law enforcement agencies, providing assistance and access to information when required to support investigations into financial crime.
10. Policy Maintenance
This policy is reviewed on a regular basis to ensure that it remains current, effective, and aligned with regulatory expectations and industry standards. Any changes are communicated to employees and relevant stakeholders.
11. Prohibited jurisdictions
Afghanistan
Central African Republic
Guinea
Iran
Lebanon
Myanmar
Russian Federation
Sudan
United States of America
Yemen
Belarus
Congo, the Democratic Republic of the
Guinea-Bissau
Iraq
Libya
Nicaragua
Somalia
Syrian Arab Republic
Ukraine
Venezuela
Zimbabwe
Burundi
Cuba
Haiti
Korea, the Democratic People’s Republic of
Mali
Palestine
South Sudan
Taiwan
Western Sahara