Anti-Money Laundering (AML) Policy

Matrixport Technologies Ltd and its affiliated entities (collectively, "BIT", formerly known as Matrixport) are committed to participating in the fight against money laundering (ML) and terrorist financing (TF), and to complying with applicable anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions requirements. These obligations, together with relevant regulatory guidelines, form the foundation of BIT's Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT) program.

Our AML/CFT framework applies to all jurisdictions where we conduct business and establishes a risk-based governance system, policy framework, execution processes, and internal control mechanisms to identify, assess, and mitigate financial crime risks, including measures for counter-proliferation financing and sanctions compliance.

Core components of the anti-money laundering program:

1. Anti-Money Laundering/Counter-Terrorist Financing Policy

The AML/CFT policy establishes the fundamental standards that BIT must comply with. This includes:

Written policies, procedures, and internal controls to ensure compliance with applicable anti-money laundering laws and regulations

Segregation of duties: Appointment of a dedicated compliance officer (MLRO) responsible for the AML program and designated compliance officers responsible for the effective execution of day-to-day compliance work.

Governance framework: Establishment of a sound governance framework to ensure senior management oversight of the AML program

Customer Due Diligence (CDD): Identification and verification of the identity of customers, authorized representatives, and (where applicable) beneficial owners; obtaining account purpose, expected transaction activity, source of funds, and, where appropriate, source of wealth information at account opening.

Risk assessment: Customer, product, service, delivery channel, and geographic risk assessment.

Enhanced Due Diligence (EDD): Applicable to high-risk relationships (e.g., Politically Exposed Persons (PEPs), high-risk industries/jurisdictions, negative media coverage, and high-risk factors from KYT/Transaction Monitoring (TM)).

Sanctions compliance: Screening and controls in accordance with relevant sanctions regime requirements, including obligations related to counter-proliferation financing.

Reporting and notification: Internal reporting processes and timely submission of suspicious transaction/activity reports to relevant regulatory authorities.

Ongoing due diligence: Periodic reviews (PRs) conducted based on risk level and trigger events.

Training: All employees must participate in AML/CFT and sanctions training upon onboarding and annually.

Independent review/testing: Regular, independent audit/assessment of program effectiveness.

Record keeping: Retention of records in accordance with applicable legal and regulatory requirements.

Wire transfer information transmission requirements (where applicable): Transmission of necessary remitter/beneficiary information

2. Prohibited Account Uses, Customers, and Business Types

Prohibited business relationships
BIT must not establish business relationships with the following customer types:

  • Individuals and entities subject to sanctions by BVI authorities or listed on international sanctions lists (e.g., UN Security Council, US Office of Foreign Assets Control (OFAC), EU sanctions, UK Treasury, Monetary Authority of Singapore, etc.).
  • Individuals or enterprises known or reasonably presumed to be involved in terrorist financing or serious criminal activities, or belonging to/supporting such organizations
  • Shell banks, i.e., banks without physical presence in their jurisdiction of registration
  • Customers operating under false names or aliases
  • Customers engaged in weapons, arms manufacturing, or arms trading
  • Customers engaged in tobacco trading
  • Customers engaged in adult entertainment industry
  • Customers engaged in casinos, gambling, or similar industries

Prohibited asset types
BIT does not allow funds identified through Know Your Transaction (KYT) monitoring or KYC checks as proceeds of crime, or used for terrorist financing, or belonging to criminal organizations, and strictly prohibits establishing business relationships with such customers, even if such customers' criminal or illegal activities occurred abroad.

Restricted regions and countries
BIT does not accept customers from restricted jurisdictions (e.g., regions under comprehensive sanctions or regions with serious AML/CFT deficiencies). The current list can be found in our Help Center. https://helpcenter.matrixport.com/en/articles/9978840-restricted-countries and reviewed at least annually.

3. BIT's KYT

BIT prohibits the use of its platform for any illegal activities, including money laundering, terrorist financing, or other illegal transaction behaviors. We implement real-time and continuous KYT and transaction monitoring for all user transactions. When monitoring detects suspected illegal activities, BIT may take measures including but not limited to: rejecting or returning funds, issuing information requests (RFI), freezing accounts, suspending or terminating accounts and service relationships, and (where applicable law and our Terms and Conditions permit) reporting suspicious activities to relevant regulatory authorities. BIT reserves all rights exercisable under applicable law and contractual agreements.

4. Prohibited Activities

The following activities are prohibited on the BIT platform, including but not limited to:

  • Transactions that may violate or cause BIT to violate applicable economic sanctions, including but not limited to sanctions implemented or enforced by the US Treasury Department's Office of Foreign Assets Control (OFAC), US State Department, UN Security Council, EU member states, UK Treasury, and Monetary Authority of Singapore. This is not an exhaustive list and also includes other applicable sanctions program measures in jurisdictions where BIT operates.
  • Transactions related to illegal activities, including fraud, scams, stolen funds, ransomware, and malware-related transactions.
  • Transactions involving mixing services/cryptocurrency tumblers, dark web markets, or other obfuscation services.
  • Transactions related to casinos, gambling, or similar industries.
  • Transactions with unusual, rare, or no reasonable business explanation patterns.