AML Policy

BillLine adheres to the highest standards in the fight with Anti Money Laundering (AML) and financial terrorism and requires that the company’s management and employees follow these standards.

Money laundering is the process of converting funds obtained as a result of illegal activities (fraud, corruption, terrorism, etc.) into other funds or investments that look legitimate, in order to conceal or distort the real sources of funds’ origin.

The following laws constitute the legal framework of Ukraine in the field of preventing and countering the legalization (laundering) of proceeds from crime or the financing of terrorism:

The Law of Ukraine on Preventing and counteracting the legalization (laundering) of proceeds from crime, financing of terrorism and financing of proliferation of weapons of mass destruction;

The Law of Ukraine on Banks and banking activities;

Criminal code of Ukraine; the Code of Administrative Offences;

The Law of Ukraine on Prevention of Corruption

The money laundering process can be divided into 3 consecutive stages:

Allocation. At this stage, funds are converted into other financial instruments such as checks, bank accounts, money transfers, or they can be used to purchase expensive goods that can be resold. Funds can also be invested in banks and non- banking institutions (for example, currency exchange offices). To avoid suspicion from the company, the money laundering person can make several investments instead of investing the entire amount at once. This form of allocation is called “smurfing” or “spray”.

Fragmentation. Funds are transferred or moved to other accounts and other financial instruments. This is done in order to hide the origin and prevent the identification of a person who has made several financial transactions. Moving money and changing its form makes it more difficult to track laundered money.

Integration. Funds are returned to the circulation as legally received for a purchase of goods or services.

AML policy

BillLine, like most organizations that provide services in the financial market, adheres to the principles of Anti Money Laundering (AML) and actively discourages any actions aimed at facilitating the process of legalizing funds obtained illegally. The AML (Anti Money Laundering) policy is intended to prevent the use of the company’s services by criminal entities for the purpose of money laundering, terrorist financing or other criminal activities.

For this purpose, the company has implemented a strict policy for detecting, preventing and notifying all suspicious transactions to the relevant authorities. However, BillLine does not have the right to inform its client that law enforcement agencies have been notified of its activities. We also implemented a complex electronic identification system for each client of the company and introduced a detailed history of all operations.

In order to prevent money laundering, BillLine does not accept or pay cash under any circumstances. The company reserves the right to suspend any client transaction that may be considered illegal or, in the opinion of employees, may be related to money laundering.

Company procedures

BillLine should make sure that it works with a real natural person or legal entity. BillLine takes all necessary measures in accordance with current laws and regulations that have been introduced on the territory of Ukraine. The AML policy is implemented by:

Know your Client policy and legal expertise;

monitoring the client’s activity;

accounting.

Since the company adheres to the AML and KYC policies, each client of the company should pass the verification procedure. Before starting any kind of work with clients, BillLine makes sure that the company will be provided with evidence or measures will be taken to provide evidence confirming the identity of any client or counterparty. The company also pays special attention to clients who are residents of countries that are recognized as reliable sources as countries with insufficient AML levels and pose a high risk due to crime and corruption, as well as to the beneficiaries and funds coming from these countries.

Natural person

During the registration, each Client provides personal information, namely: full name, date of birth, country of residence, full address, including phone number and city code. In order to meet the company’s KYC and identity verification requirements, as well as to confirm the specified information, if it is necessary, Clients- natural person should provide the following documents upon request of the Company:

A good quality copy of a government-issued identity document containing: full name, date of birth, photo with indication of nationality, as well as, if it is necessary, proof of validity of the document (date of issue / expiration), signature of the holder. This identity document can be a passport, national ID card, driver’s license, or other similar document. These documents should be valid for at least 6 months from the date of submission for review. The company reserves the right to request certified copies of identification documents; in this case the certification should not be older than 6 months from the date of submission for review. The company reserves the right to request another identity document.

Accepting new clients during verification and documents review, the Company reserves the right to apply other requirements and procedures for Customer identification. Such procedures are determined by the company at its own discretion depending on the Client’s country of residence and can include, but are not limited to:

the need to provide a Bank card that is used for deposits / withdrawals funds;

the need to provide a source of funds, a source of origin of funds and confirmation of funds used to deposit, in such form and in such way that the Company regards as satisfactory.

Legal entity

A copy of the extract from USREOU code

A copy of the duly registered constituent document of the current version with all applicable appendices to the document, subject to availability (charter / constituent agreement / constituent act /regulations). Legal entities of public law that act on the basis of laws do not submit a constituent document. Legal entity established and / or operates under the model charter, approved by the Cabinet of Ministers of Ukraine, submits a copy of the decision on its establishment or implementation activities on the basis of model charter of Association signed by all founders.

A copy of orders and protocols, the decision of the owners to appoint persons who have the right to dispose of the property and funds of a legal entity.

Copy of the passport of the citizen of Ukraine (or other document proving the identity according to the legislation of Ukraine can be used on the territory of Ukraine for transactions) person who has the right to dispose of property and funds of a legal entity.

A copy of the certificate of national identification number or copy of the passport of the citizen of Ukraine, which is stamped on the refusal to accept the registration number of the payer taxes of the Ukraine the person who has the right to dispose of property and funds of a legal entity.

The Client’s ownership structure is in the schematic image.

This procedure is performed to establish the client’s identity and help BillLine to learn / understand clients and their financial transactions in order to provide better services.

Monitoring client activity

In addition to collecting information about clients, Beeline continues to monitor each client’s activity in order to detect and prevent any suspicious transactions. A suspicious transaction is an operation that contradicts the client’s legitimate business or normal transaction history in accordance with the monitoring of the client’s activity. Beeline has implemented a system for monitoring these operations (both automatic and, if it is necessary, manually) to prevent criminals from using the company’s services.