Anti-Money Laundering Policy

Last updated: January 1, 2025

1. Introduction and Purpose

BitVori is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures to prevent our platform from being used for money laundering, terrorist financing, or other financial crimes.

We comply with applicable Ugandan laws, including the Anti-Money Laundering Act, 2013, and international standards set by the Financial Action Task Force (FATF).

2. Know Your Customer (KYC)

All users must complete identity verification before using our services. Our KYC process includes:

Basic Verification

  • Full legal name
  • Date of birth
  • Email address

Enhanced Verification

  • Government-issued photo ID (National ID, Passport, or Driver's License)
  • Proof of address (utility bill, bank statement)
  • Selfie for facial recognition verification
  • Source of funds declaration for larger investments

3. Customer Due Diligence (CDD)

We conduct due diligence on all customers:

  • Standard CDD: For all users during registration
  • Enhanced CDD: For high-risk customers, large transactions, or politically exposed persons (PEPs)
  • Ongoing Monitoring: Continuous review of customer activity and transactions

4. Transaction Monitoring

We employ automated systems and manual reviews to monitor transactions for suspicious activity:

  • Real-time transaction screening
  • Pattern recognition for unusual activity
  • Threshold-based alerts for large transactions
  • Velocity checks for rapid or frequent transactions
  • Geographic risk assessment

5. Suspicious Activity Reporting

When we identify suspicious activity, we:

  • Document and investigate the activity internally
  • File Suspicious Transaction Reports (STRs) with the Financial Intelligence Authority (FIA) of Uganda
  • Cooperate fully with law enforcement investigations
  • Preserve records as required by law

We are prohibited from informing customers that an STR has been filed ("tipping off").

6. Politically Exposed Persons (PEPs)

We apply enhanced due diligence to PEPs, which includes:

  • Senior government officials and their families
  • Senior executives of state-owned enterprises
  • Senior political party officials
  • Senior judicial or military officials

PEPs are subject to enhanced monitoring and may face additional documentation requirements.

7. Sanctions Compliance

We screen all users and transactions against:

  • United Nations Security Council sanctions lists
  • OFAC (U.S. Treasury) sanctions lists
  • EU sanctions lists
  • Local regulatory sanctions lists

Transactions involving sanctioned individuals, entities, or countries are prohibited.

8. Record Keeping

We maintain comprehensive records including:

  • Customer identification documents
  • Transaction records
  • Account files and correspondence
  • AML training records

Records are retained for a minimum of 10 years after the business relationship ends or the transaction is completed.

9. Staff Training

All employees receive regular AML training covering:

  • Recognition of suspicious activity
  • KYC and CDD procedures
  • Reporting obligations
  • Latest regulatory developments
  • Cryptocurrency-specific risks

10. Compliance Officer

Our designated Money Laundering Reporting Officer (MLRO) is responsible for:

  • Overseeing AML compliance program
  • Receiving and investigating internal reports
  • Filing STRs with authorities
  • Liaising with regulators
  • Updating policies and procedures

11. Prohibited Activities

The following activities are strictly prohibited on our platform:

  • Money laundering in any form
  • Terrorist financing
  • Fraud or identity theft
  • Transactions with sanctioned parties
  • Use of anonymizing services to obscure transaction origins
  • Structuring transactions to avoid reporting thresholds

12. Contact Information

For AML-related inquiries, please contact:

Email: [email protected]