Legal Information

BIT TRADE AUSTRALIA

AML & FINANCIAL CRIME PREVENTION PROGRAM (DISCLOSURE STATEMENT)

The Australian Government introduced the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 in response to global pressures to strengthen Australia?s ability to detect and prevent money laundering and terrorism financing.  As one of the country?s leading digital currency providers, Bit Trade Australia takes the implementation of the AML/CTF Act seriously and has voluntarily taken comprehensive steps to implement an assertive AML/CTF Program which is benchmarked against the obligations set out with-in the AML/CTF Act and the AML/CTF Rule-set.

Key Components of BTA's Responsibilities in our AML/CTF Program

Oversight by our Board and Senior Management

Bit Trade Australia Pty Ltd's AML/CTF program has been approved at Directorial-Board level and has ongoing oversight via Operational Management, Compliance Committee and business reporting structures.

AML/CTF Compliance Officer

Bit Trade Australia has appointed a CA qualified, AML/CTF Compliance Officer at a Senior Management level who has the responsibility for the AML/CTF Program including the oversight of Risk Registry/Mitigation and External Auditing engagement, supported by an internal compliance committee.

Employee Training

Bit Trade Australia has appropriate AML/CTF Risk Awareness Training in place, externally through Drake Training, and internally through our Banking and Finance Manager, with a corporate training retail-banking sector background, to assist staff to understand our AML/CTF-related obligations, including the risks faced by us, the consequences to us of non-compliance and the procedures and processes we have in place.

This training is undertaken on a recurring cycle or when legislative changes may dictate.

Employee Due Diligence

Bit Trade Australia has robust procedures and processes in place to ensure that employees are subject to the appropriate background checks to mitigate the risk of them using their position to facilitate money laundering or terrorism financing as well as ongoing control mechanisms.

Background checks are conducted by a 3rd party service provider and include the following:

Independent Review of our AML/CTF Program

Bit Trade Australia?s AML/CTF Program is voluntarily subject to independent reviews conducted by an External Audit department to assess the effectiveness of our risk based controls and ensure compliance with the AML/CTF Program.

Frequency is risk based and determined on business requirements. Reports are provided through to Senior Directorship and the Internal Audit Committee.

Record Keeping

Bit Trade Australia has implemented processes and procedures to ensure that records made in respect of customer identification are held for 7 years after the end of the relationship. Other documentation will be retained for the length of time required to meet our Best Practice obligations or a minimum of 3 years.

Know Your Customer

Bit Trade Australia introduced a risk based methodology based on the requirements of the AML/CTF Act and Rules to collect and verify certain information to confirm customer identities. In most cases, this occurs at the point of time of on boarding a new customer or entity. Controls, processes and procedures have been developed to capture this information based on Bit Trade Australia ?s risk tolerance and are primarily conducted through Edentiti Pty Ltd via the GreenID verification check. Edentiti Pty Ltd is the inaugural gateway service provider to the the Office of the Attorney General?s Document Verification Service.

Know Your Customer/Electronic Know Your Customer and Ongoing Customer Due Diligence/Enhanced Customer Due Diligence are also available or subject to Traditional and/or Manual processing procedures.

Suspicious Matter Reporting

Bit Trade Australia has implemented controls, processes and procedures to detect and report suspicious activities and transactions to relevant state or federal authorities.

Transaction Reporting

Bit Trade Australia has voluntarily developed and implemented controls, processes and procedure to keep records of the following transactional details as would be required by the following:

Risk Management Program

Bit Trade Australia Pty Ltd has drafted its Operational Manual-Service Guide and has implemented its Risk Management policies/process?s in-line with AS/NZS ISO 31000:2009 standards.

Exclusions & Sanctions

Bit Trade Australia has implemented controls and processes to monitor customers and transactions against prescribed lists and/or Transaction Monitoring Process (TMP) Trigger Points, to ensure that we do not knowingly participate in any transaction that facilitates terrorism financing,  breaches Australian law or violates any part of the the laws, which apply to traditional and financial sector participants.

Correspondent Exchanges

Bit Trade Australia has implemented processes and procedures to ensure that we will:

Administrative Information for Correspondent Banking and DC Exchange Due Diligence

Operating Entity: Bit Trade Australia Pty Ltd

Registered Address: SE 2.02/39 Liverpool Street, Commerce Buildings, Sydney NSW 2000, Australia

KYC/AML-CTF Compliance Program Contact Details:

AML/CTF Contact: BTA Compliance Officer, Mr. D. Fenner MBA CA

Mailing Address: PO Box 21122 World Square Sydney, NSW AUSTRALIA 2002

For further information please email: complianceofficer@btradeaustralia.com

General Legal Consul:

GILBERT + TOBIN LAWYERS

GPO Box 3810 Sydney NSW
Australia 2000
DX 10348 SSE

Financial Services Legal Consul:

HOLLEY-NETHERCOTE COMMERCIAL & FINANCIAL SERVICES LAWYERS

GPO Box 3045
Melbourne VIC
Australia 3001

The Australian Digital Currency Commerce Association (ADCCA)

Bit Trade Australia is a  member of the ADCCA. This industry body is the country?s leading council and representation of and for digital currency businesses along with other key financial sector participants. With a founding mandate to 'act as the essential connection between merchants, industry, governments, regulators, financial institutions and influential policy forums',  the ADCCA is in a consultative study process actively engaging with key-stake-holders whilst drafting a set of DC business Best Practices, Standards and Code of Ethics. BTA is committed to supporting this organisation to ensure a robust, world-class framework continues to evolve with-in Australia.

Consumer and Website Visitor Online Safety Education and Awareness:

Bit Trade Australia Pty Ltd maintains a page on its website dedicated to educating on-line visitors and customers of the risks involved in internet fraud. This page serves help educate how best to avoid eFraud, scams and mitigate risks to known tactics used by cyber-criminals. Bit Trade Australia also provides suggested steps for contacting the appropriate authorities to report suspected illegal activity.

This page is available through the following link:

https://www.btradeaustralia.com/protect-yourself-online/

Contact Details

AML/CTF Contact: AML/CTF Compliance Officer [EDF100006]

Mailing Address: BTA PO Box 21122 World Square, Sydney NSW 2002

For further information please email: complianceofficer@btradeuastralia.com

Bit Trade Australia Pty Ltd
ABN 42 163 237 634
ACN 163 237 634
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