Bit One Hong Kong Ltd. (herein after referred as “our company”) reiterates and clearly stipulates our determination to prevent money laundering and terrorist financing (both of them will be herein after referred as “money laundering, etc.”). Money laundering means “acts to disguise and/or conceal profits from crimes for the purpose of camouflaging illegal origins”, and terrorist financing means “to provide funds necessary for terrorists to carry out terrorisms”. Leaving such acts will lead to letting profits from crimes be used for criminal activities in the future, and also letting criminal syndicates affect power on lawful economic activities. Therefore, prevention of money laundering is becoming a major issue inside and outside Japan. Furthermore, money laundering, etc. is becoming more internationalized, dexterous, and complicated in recent years, and therefore international coordination is strongly required for its protection.
Cryptocurrencies dealt with us have natures such as high anonymity of users, and can be promptly and internationally transferred. As each country has different regulations against cryptocurrencies, it has been pointed out that tracing profits from crimes will be difficult when cryptocurrencies are exploited for such crimes. Our company, globally dealing with cryptocurrencies, strongly recognizes importance of preventive measures against money laundering, etc., and organizes the following internal management system to perform businesses in order to meet severe requests from the international society.
1. Organizational System
Our board of directors, the highest organization for making decisions, considers establishment of a prevention system against money laundering, etc. as our most important business matter, and will have a lot of involvement in it. The board of directors establishes policies, standards, and management guidelines to prevent money laundering, etc. We also establish an organization to prevent money laundering, etc., appoint people in charge, make them always collect information about money laundering, etc., response appropriately, and make regular or timely reports.
2. Management Policy
Our company builds a risk management system to prevent money laundering, etc., in order to clarify the roles in the company, and carry out and appropriate actions in a timely manner.
3. Identification Confirmation
Our company makes arrangements required to carry out appropriate actions in a timely manner for identification confirmation, etc.
4. Notification of Suspicious Transactions
Our company promptly notifies “suspicious transactions” that are detected through transaction monitoring, to the authorities.
5. Training of Officers and Employees
Our company regularly attends training for all officers and employees, and external training for the staff in charge of AML, in order to make them obtain knowledge and improve awareness to prevent money laundering, etc.
6. Audit of the Status of Compliance
Our company regularly audits the status of compliance with regard to preventive measures against money laundering, etc. by independent auditors, in order to improve the system based on the results of the audit.
Applicable Legislations on AML/CTF in Hong Kong
(1)AML/CTF laws and regulations
- Cap. 615ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING ORDINACE
- Cap. 405)DRUG TRAFFICKING (RECOVERY OF PROCEEDS) ORDINANCE
- Cap. 455ORGANIZED AND SERIOUS CRIMES ORDINANCE
- Cap. 575UNITED NATIONS(ANTI-TERRORISM MEASURES) ORDINANCE
- Cap. 537 United Nations Sanctions Ordinance
- Cap. 526 Weapons of mass destruction
(2)Industry Supervision Law and Regulations
- Cap. 155 Banking Ordinance
- Cap. 571 Securities and Futures Ordinance
- Cap. 41 Insurance Ordinanceestruction