Anti-Money Laundering and Counter-Terrorist Financing Obligations

1. Introduction

“BCASH Greece INC” (hereinafter referred to as “the Company”), a Virtual Asset Provider under the Directive (EU) 2018/843, being transposed into the Greek legislation by Law 4734/2020, is an obliged entity in the sense that it has to meet several obligations, among others, such as:

• Establishing and maintaining a risk-based approach on Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence (EDD) for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).
• monitoring of on-going customer activity.
• reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate.
• Maintaining appropriate records for the minimum prescribed periods, namely for five (5) years following the termination of the relationship.

Virtual currencies are developing quickly and are an example of digital innovation.  However, at the same time, there is a risk that virtual currencies could be used by terrorist organizations or other malicious entities to circumvent the traditional financial system and conceal financial transactions as these can be carried out in an anonymous manner. The HCMC on March 31, 2021 included “BCASH GREECE INC” in the register of providers of exchange services between virtual currencies and fiat currencies (“Providers of Exchange Services Between Virtual Currencies and Fiat Currencies registered in the register kept by the Hellenic Capital Market Commission according to Article 6(1)(B) of Law 4557/2018”). Therefore, the Company is committed to applying the highest level of standards in order to manage Money Laundering (ML) and Terrorist Financing (TF) risks and ensure transparency in its business activities. The Company requires its clients to adhere to these standards prior to any transaction in order to prevent use of the services for money laundering purposes, terrorist financing and other illegal activities.

 

2. Know Your Customer (Identification, Verification, Customer Due Diligence)

In order to use our services, the Company will need to ask from its clients to identify themselves. Client identification and transaction monitoring as processes might contain verification of the client’s identity on the basis of documents, personal data or information obtained from a reliable and independent source, communications of the client with the Company, IP addresses location and online activity observation.

Moreover, it is highly possible that, in case of ML/TF suspicion at any time, regardless of any derogation, exemption, or threshold, the Company will ask further details (personal data and document submission) from the client in order to verify the latter’s identity and to ensure the legitimacy of the transaction, without prior notice, or might even indiscriminately refuse any transaction.

Clients will have to open an “account” with the Company by providing personal information, documentation and non-face-to-face identification/digital onboarding processes (selfie, liveness test). The verification level (personal information, documentation, digital onboarding) depends on the three different transactional levels the Company offers to its customers.

Personal Information and Documentation: may include but not be limited to your: Name, Surname, Father’s Name, Date of Birth, Place of Birth, Sex, Address - Postal Code of Residence or Business address, Citizenship, Identity document type and number, Country and Authority that issued the Identity Document, expiration date of Identity Document, TIN Number, profession, mail address, mobile phone number, IP addresses.

In addition, legal entities among others must provide: The Article of Incorporation, decisions amending the Article of Incorporation, decision of the General Meeting with which the Board of Directors was appointed, Notarial Deed (representation of the company). The ultimate beneficiary and the other individuals who represent the legal entity must provide the above-mentioned information and documentation (name, surname, date of birth etc.).   

At any time, we may require by your side to provide documentation in order to verify your personal information (e.g. your Identification Document, utility bills etc.).

The Company reserves the right to suspend or terminate your account/transaction at any time if:

• The customer denies providing appropriate documentation/information for the verification of his identity or justification of a transaction.
• The customer provides false contact details or any other false information.
• The customer provides counterfeit documentation.
• There is suspicion of violating any of the offences mentioned in the competent Laws.
• The regulator or other competent authority asks us to do so.

 

3. Personal Data Processing

We collect and process your personal data only for and to the extent we must in order to be compliant with the Anti Money Laundering/Countering Terrorism Financing Legislation demands.

The Company keeps records of all transactions and all identification documents, and will retain all information, including those obtained through electronic identification means for a period of at least five (5) years after the end of the business relationship with the client or after the date of an occasional transaction.

The Company is compliant with the Regulation (EU) 2016/679, commonly known as General Data Protection Regulation (GDPR). Personal data are collected, processed and stored for Anti-Money Laundering obligations that our institution must fulfil.

For more information about your personal data collection/processing please refer to our Privacy terms.

 

4. Transactions Limits and Levels:

 

Level 0

Up to € 1.000,00 / Customer

Identification Requirements:

• Verified mobile phone
• Verified e-mail address

 

Level 1

Quarter

up to € 12.000,00

Identification Requirements:

• Level 0, plus:
• Full Name / Company Name
• Date of Birth / Date of Incorporation
• Nationality / Country of Activity and of Establishment
• Residential Address & ZIP code
• Personal ID or Passport or Driving License or Residence Permit. For legal entities, the Identification Document of the ultimate beneficiary owner and/or (depending the legal form of the company) of the legal representative.

 

Level 2

Monthly Limit

up to € 14.990,00

Identification Requirements:

• Level 1 plus:
• Occupation / Business Activity
• Proof of Address.

 

Level 3

Weekly Limit	Monthly Limit
from € 15.000,00	Up to tbd According to TAX ID

Identification Requirements:

• Level 2 plus:
• Income tax form / Submitted Income Tax Return for legal entities
• Proof of funds
• Account Purpose
• Digital Onboarding (selfie, liveness test) or In-Person Verification

 

The Company reserves the right to alter the limitations, levels and identification requirements at any time.