BSA/AML POLICY OVERVIEW
It is the policy of Coinmover to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.
Money laundering is generally defined as “engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.”
Generally, money laundering occurs in three stages. Illicit proceeds first enter the financial system at the “placement” stage, where funds generated from criminal activities are converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other assets, accounts, or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership, and personal employment.
Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.
In order to provide you with our services, we need you to agree to the rules in this document set forth by the government and we can’t accept illegitimate or illegal funds.
OUR INTERNAL CONTROLS
CoinMover’s Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Policy is required by federal regulation. We are considered a Money Service Business (‘MSB’) in that we fall under the definition of a money transmitter as dictated by the United States Treasury, Financial Crimes Enforcement Network (FinCEN). Our registration (#31000175484623) was issued November 4, 2018. This information is publicly available on the FinCEN website.
CoinMover’s BSA/AML policies and internal controls are designed to ensure compliance with all applicable BSA and AML regulations and will be regularly reviewed, independently audited, and updated on a regular basis to account for both changes in regulations and changes in CoinMover’s policies to follow said regulations.
CoinMover’s BSA/AML policies set forth the standards of compliance and establish a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to our institution.
CoinMover prohibits transactions with individuals, entities, and countries that are on prescribed sanctions lists and therefore screen against U.N., E.U., U.K. Treasury, U.S. Office of Foreign Assets Control (OFAC), and other sanctions lists in the jurisdictions in which we operate.
We’re registered with the government and we can’t do business with people or organizations they have on a list somewhere, or that are doing bad things, so we have checks in place to make sure we adhere to the rules.
APPLICABILITY AND SCOPE
FinCEN’s BSA/AML regulatory requirements are applicable to CoinMover under FinCEN Guidance FIN-2013-G001. CoinMover operates a multistate network of automated cryptocurrency kiosks (“kiosks”) which enable customers to perform three exchange services:
- U.S. dollar-denominated cash (or “fiat money”) for cryptocurrency;
- cryptocurrency for cash (or “fiat money”);
- cryptocurrency for cryptocurrency (or “crypto-to-crypto”).
As such, and in response to the threat of potential money laundering activities conducted via its exchange services, CoinMover has adopted an anti-money laundering policy, as summarized above, which is followed by all of its employees, officers, agents, owners, and directors.
Reference: FinCEN Guidance FIN-2013-G001 “Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies.” [external link to FinCEN website and regulations]
We sell you cryptocurrency in exchange for USD which makes us a “money transmitter” per the government, so we follow all FinCEN and state rules and regulations.
WHAT THIS MEANS FOR YOU
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This includes advanced Know Your Customer (‘KYC’) regulations, Customer Identification Procedures (‘CIP’) and Enhanced Due Diligence (‘EDD’) policies.
This means that CoinMover, when conducting a transaction at one of the kiosks, will ask you to provide information so that we may reasonably identify you in compliance with the Bank Secrecy Act of 1970, the USA PATRIOT Act, and other various regulations set forth by the government.
We may also ask you to provide your driver’s license or other identifying documents. When you try to buy over $9,000 or reach a cumulitive amount that gets into six figures, we ask for even more information about your Source of Funds (‘SOF’) and/or Proof of Funds (‘POF’). This is to ensure can make sure the amount being transacted is supported by your documentation or income.
We will retain copies of all identifying information you provide.
To do all of this, we need information from you. You can chose to provide it or choose not use our services. We’ll keep this information on file and give it to the government if requests it.