Modern

Anti Money Laundering (AML) and Know Your Customer (KYC) Policy


Bitspark is committed to providing a reputable, reliable and secure service with high standards of integrity and transparency, in full compliance with applicable laws and global standards.

As a licensed Money Services Operator registered in Hong Kong, we are required to take measures to prevent the use of our services for money laundering and the financing of terrorism and criminal activities such as drug trafficking.

We therefore have a robust anti money laundering (AML) policy to comply with such laws and UN sanctions, and because we believe that bitcoin and cryptocurrencies are a disruptive innovation offering significant benefits to commerce.

We adopt Know Your Customer (KYC) principles and customer due diligence (CDD) to obtain information such as identity and address to understand your needs, source of funds and intended use, depending on our products and service offering, taking into consideration a range of factors.

Opening an account constitutes acceptance of these conditions and our terms of use.

Registration and Sign up

You can sign up quickly and easily by providing your name, email address, choosing a username and password. This will provide the opportunity to transact in crypto-currencies [up to a maximum of $120 000 HKD equivalent monthly]. Above this limit, you will need to have your identity verified (see below). Or to transact in fiat currencies you will be required to verify your account.

We reserve the right to refuse or cancel accounts with anonymous or fictitious names, or attempts to create multiple accounts for the same user (or IP address, unless verified). We may also refuse registration to customers in jurisdictions that do not meet international AML standards, are subject to sanctions, or users who could be considered a politically exposed person, as required by law.

Verification

To deposit or withdraw fiat currency [above the equivalent of HK$8000], or to make transactions above the equivalent of HK$120 000, we will need to verify your identity. This will require a government photo ID showing your full name and date of birth, and proof of address. Valid ID includes a national identity card, passport, driver’s license, and proof of address includes a bank statement or utility bill. If this is not in English it will need to be confirmed by a relevant authority like an accountant, lawyer, solicitor, Justice of the Peace or government body.

In unusual cases, or for users from certain countries, we may require additional identification information, or information on the purpose and intended nature of the relationship. When dealing with corporate users, in most cases we will need to identify ultimate beneficial owners. Accounts will remain unverified with limited functionality until we receive and accept such information.

Wire transfers and cryptocurrency remittances

When an account is verified, and a fiat transaction is made, we will require and record certain information such as your name, account number or unique reference number, address or ID number, date and place of birth, to meet international wire transfer and remittance requirements. We may refuse or cancel the transaction if the information is insufficient or cannot be obtained.

Monitoring and Review

We operate procedures to monitor ongoing customer activity and may seek further information where transactions appear unusual, irregular, or suspicious.

In rare or exceptional cases we may refuse to process, cancel or (where possible) reverse a transaction if we suspect the transaction is related to money laundering, terrorist financing, the proceeds of crime or drug trafficking, in response to a court or governmental order, or if the transaction is otherwise deemed unacceptably high risk.

We will periodically review customer documents and information to ensure they are relevant and up to date and may request further information, including if we have reason to doubt the veracity or adequacy of any information previously obtained for the purpose of identification or verification.

We train our staff in anti money laundering and financing of terrorism compliance, and also review all of our policies and processes on a continual basis to ensure we continue to operate best practice.

Account Suspension and Cancellation

We may suspend access to any or all services, or cancel an account at any time at our discretion and without liability or disclosing the reason. We will notify you after exercising rights under this clause. This may occur where required by law or directed by relevant authorities, or if we reasonably suspect use of the account for illegal activities, or actions not in good faith, such as attempts to abuse the platform or circumvent controls.

You may cancel an account at any time by notifying us, after which cleared bitcoin or fiat currency will be refunded (unless prohibited by the above).

Record Keeping

We will retain and store securely transaction records for six years, and identification information and correspondence for six years after our relationship ceases, as required by law or relevant authority.

Use of an Intermediary, Third Party or Service Provider

We may carry out KYC and CDD or banking services by means of a licensed intermediary, third party or service provider, in an equivalent jurisdiction who will be subject to the same standards and obligations as Bitspark in Hong Kong, ie Financial Action Task Force (FATF) standards.

Tax Obligations

It is a user’s sole responsibility to determine whether and to what extent, depending upon their location, any taxes apply to crypto-currency transactions conducted through Bitspark, and to report and remit the appropriate amount of tax to relevant authorities. A transaction history is available in each account to assist with this.