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

Last Updated: January 25, 2025

1. Policy Statement

BiTraider Inc. ("BiTraider") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines our procedures for compliance with applicable laws and regulations, including:

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• State-level money transmission regulations

2. Regulatory Compliance

2.1 Money Transmission

BiTraider facilitates cryptocurrency transactions and operates as a money services business (MSB) where applicable. We maintain appropriate licensing and registration with:

• Financial Crimes Enforcement Network (FinCEN)
• State regulatory authorities as required

2.2 Compliance Officer

BiTraider has designated a Compliance Officer responsible for:

• Overseeing AML/KYC program implementation
• Ensuring regulatory compliance
• Conducting employee training
• Reviewing and updating policies
• Liaising with regulatory authorities

Contact: compliance@boneyard.io

3. Know Your Customer (KYC) Requirements

3.1 Customer Identification Program (CIP)

Before providing services, we verify the identity of all customers through our Customer Identification Program.

3.2 Required Information

We collect the following information from all customers:

• Full Legal Name
• Date of Birth
• Residential Address (P.O. boxes not accepted for primary residence)
• Phone Number
• Government-Issued ID Number (e.g., Social Security Number, Driver's License, Passport)

3.3 Document Verification

Customers must provide copies of acceptable identification documents:

Primary ID (one required):

• Passport
• Driver's License
• State-issued ID card
• National ID card

Secondary Verification (may be required):

• Utility bill (not older than 3 months)
• Bank statement
• Government correspondence

3.4 Verification Levels

BiTraider implements tiered verification levels with corresponding transaction limits:

Level 1 - Basic Verification

• Phone number verification
• Basic personal information
• Limits: $500 per transaction, $500 daily, $1,000 weekly, $2,000 monthly

Level 2 - Enhanced Verification

• Government-issued ID verification
• Selfie verification (liveness check)
• Address verification
• Limits: $2,500 per transaction, $2,500 daily, $5,000 weekly, $10,000 monthly

Level 3 - Full Verification

• All Level 2 requirements
• Proof of address
• Enhanced due diligence questionnaire
• Limits: $10,000 per transaction, $10,000 daily, $20,000 weekly, $50,000 monthly

3.5 Identity Verification Process

We use third-party identity verification services to:

• Authenticate government-issued documents
• Perform liveness detection to prevent fraud
• Cross-reference information against public databases
• Screen against sanctions lists and PEP databases

4. Customer Due Diligence (CDD)

4.1 Risk Assessment

We assess customer risk based on:

• Transaction volume and frequency
• Geographic location
• Source of funds
• Occupation and business activities
• Behavioral patterns

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required for:

• High-risk customers
• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Large transaction volumes
• Unusual transaction patterns

4.3 Ongoing Monitoring

We continuously monitor customer accounts for:

• Unusual transaction patterns
• Transactions inconsistent with customer profile
• Rapid movement of funds
• Structuring or attempts to avoid reporting thresholds

5. Transaction Monitoring

5.1 Automated Monitoring

We employ automated systems to monitor transactions for suspicious activity, including:

• Large or unusual transactions
• Rapid deposit and withdrawal patterns
• Transactions involving high-risk jurisdictions
• Structuring or splitting transactions
• Transactions with no apparent economic purpose

5.2 Red Flags

Transactions triggering additional review include:

• Transactions just below reporting thresholds
• Multiple transactions in rapid succession
• Inconsistency with stated occupation or income
• Reluctance to provide information
• Use of multiple identities or accounts
• Transactions involving sanctioned countries

5.3 Transaction Limits

Transaction limits are enforced based on verification level (see Section 3.4).

6. Sanctions Screening

6.1 OFAC Compliance

BiTraider screens all customers and transactions against:

• Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list
• OFAC sanctions programs
• United Nations sanctions lists
• European Union sanctions lists
• Other relevant sanctions and watch lists

6.2 Prohibited Jurisdictions

BiTraider does not provide services to individuals or entities in jurisdictions subject to comprehensive U.S. sanctions, including:

• Cuba
• Iran
• North Korea
• Syria
• Crimea region of Ukraine
• Other jurisdictions as designated by OFAC

6.3 Screening Frequency

• All customers screened at account creation
• Ongoing screening against updated sanctions lists
• Transaction-level screening for high-risk indicators

7. Suspicious Activity Reporting

7.1 Suspicious Activity Reports (SARs)

BiTraider files Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Transactions involving $5,000 or more where we know, suspect, or have reason to suspect the transaction involves illegal funds or violates laws
• Transactions designed to evade BSA requirements
• Transactions with no apparent lawful purpose

7.2 Filing Timeline

• SARs filed within 30 days of detection
• Extension to 60 days if additional information needed

7.3 Confidentiality

The filing of SARs is kept strictly confidential. We do not disclose to the customer or any third party that a SAR has been filed.

8. Currency Transaction Reporting (CTR)

8.1 Reporting Requirements

For cash transactions exceeding $10,000 (or multiple related transactions totaling more than $10,000 in a single day), we file Currency Transaction Reports (CTRs) with FinCEN.

8.2 Cash Transaction Limits

To maintain compliance and security, BiTraider limits cash transactions processed through our agent network. Large cash transactions may require additional verification.

9. Record Retention

9.1 Required Records

We maintain records for at least five (5) years:

• Customer identification information
• Transaction records
• Correspondence and communications
• Account opening documents
• SARs and supporting documentation
• CTRs and supporting documentation

9.2 Record Security

All records are stored securely with appropriate access controls and encryption.

10. Agent Compliance

10.1 Agent Responsibilities

Independent agents who facilitate transactions on our platform must:

• Complete AML/KYC training
• Verify customer identity for in-person transactions
• Report suspicious activity to BiTraider
• Comply with transaction limits and procedures
• Maintain confidentiality of customer information

10.2 Agent Monitoring

BiTraider monitors agent activity for:

• Unusual transaction patterns
• Compliance violations
• Customer complaints
• Suspicious behavior

10.3 Agent Termination

Agents found to violate AML/KYC policies are immediately suspended and may be permanently terminated from the platform.

11. Training and Education

11.1 Employee Training

All BiTraider employees receive regular AML/KYC training covering:

• Money laundering and terrorist financing risks
• Identification and reporting of suspicious activity
• Sanctions compliance
• Company policies and procedures
• Regulatory requirements

11.2 Agent Training

Independent agents complete mandatory training before facilitating transactions.

12. Independent Testing

BiTraider conducts annual independent testing of our AML program to ensure effectiveness and compliance with regulations.

13. Customer Rights and Responsibilities

13.1 Account Restrictions

BiTraider may restrict, suspend, or terminate accounts if:

• Customer fails to complete identity verification
• Suspicious activity is detected
• Customer is on sanctions lists
• Required by law or regulation

13.2 Information Requests

Customers must respond promptly to requests for additional information or documentation. Failure to respond may result in account restrictions.

14. Reporting Suspicious Activity

If you become aware of suspicious activity on the platform, please report it immediately:

Compliance Department: compliance@boneyard.io
General Contact: admin@boneyard.io

15. Policy Updates

This policy is reviewed and updated at least annually, or more frequently as regulations change. Material updates will be communicated to customers.

16. Contact Information

For questions about our AML/KYC policies:

Compliance Officer: compliance@boneyard.io
General Inquiries: admin@boneyard.io

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BiTraider is committed to the highest standards of anti-money laundering and counter-terrorist financing compliance.