AML Compliance Policy

1.1 Purpose and Scope

The Bitcoin Corporation LTD is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy establishes our framework for preventing the use of our company for money laundering or terrorist financing purposes.

This AML policy applies to:

• All equity investments in The Bitcoin Corporation LTD
• All subsidiary token operations and transactions
• All directors, officers, and employees
• All third-party relationships and partnerships
• All jurisdictions where we operate or accept investments

1.2 Regulatory Framework

Our AML program complies with:

• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000 and 2006
• Criminal Finances Act 2017
• Financial Action Task Force (FATF) Recommendations
• EU Anti-Money Laundering Directives (as applicable)
• UK Sanctions Regulations

1.3 Money Laundering Definition

Money laundering involves disguising the origins of illegally obtained funds to make them appear legitimate. The three stages of money laundering are:

2.1 Risk-Based Approach

We employ a risk-based approach to AML compliance, categorizing investors and transactions based on inherent risk factors:

2.2 Geographic Risk

Enhanced scrutiny is applied to investors from or connected to:

• Countries subject to UN, UK, EU, or US sanctions
• FATF-identified high-risk jurisdictions
• Countries with significant corruption levels (Transparency International index)
• Known tax havens without adequate transparency
• Conflict zones or areas of political instability

2.3 Product Risk

As an equity investment in a technology company with blockchain exposure, specific risks include:

• Potential for rapid value appreciation attracting illicit funds
• Cross-border nature of blockchain transactions
• Pseudonymous nature of cryptocurrency sources
• Complexity of corporate structures in tech investments
• High-value transactions requiring enhanced scrutiny

3.1 Standard Due Diligence

All investors undergo standard customer due diligence (CDD) including:

• Identity verification using government-issued documents
• Residential address verification
• Understanding the purpose and nature of the investment
• Source of funds verification
• Sanctions and PEP screening
• Adverse media checks

3.2 Enhanced Due Diligence

Enhanced due diligence (EDD) is required for high-risk investors and includes:

• Detailed source of wealth investigation
• Independent verification of information
• Senior management approval for relationship
• More frequent ongoing monitoring
• Restrictions on transaction types or amounts
• Collection of additional documentation
• Possible site visits or video verification

3.3 Simplified Due Diligence

Simplified due diligence may apply only to:

• UK-regulated financial institutions
• Government bodies or state-owned enterprises
• Listed companies on recognized exchanges
• Regulated pension funds

Note: Simplified due diligence still requires identity verification and sanctions screening.

4.1 Monitoring Systems

All transactions are subject to automated and manual monitoring for:

• Unusual patterns or volumes relative to investor profile
• Transactions with high-risk jurisdictions
• Rapid movement of funds in and out
• Structuring to avoid reporting thresholds
• Transactions inconsistent with stated investment purpose
• Multiple investors with connected characteristics

4.2 Red Flag Indicators

4.3 Investigation Procedures

When suspicious activity is detected:

1. Immediate escalation to Money Laundering Reporting Officer (MLRO)
2. Preservation of all relevant documentation
3. Enhanced monitoring of the relationship
4. Decision on whether to file a Suspicious Activity Report (SAR)
5. Consideration of relationship termination
6. No tipping off the subject of investigation

5.1 Suspicious Activity Reports

The MLRO is responsible for filing Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) when:

• Knowledge or suspicion of money laundering exists
• Reasonable grounds for suspicion are identified
• Information comes to light during business activities

SAR filing requirements:

• Filed within 24 hours of suspicion arising
• Contains all relevant information and documentation
• Maintains strict confidentiality (tipping off is a criminal offense)
• Await NCA consent before proceeding with transactions

5.2 Internal Reporting

All employees must immediately report to the MLRO:

• Any suspicious transactions or activities
• Attempts to avoid compliance procedures
• Threats or attempts at bribery
• Requests to falsify information
• Discovery of false or misleading information

5.3 Regulatory Reporting

Regular reports provided to regulators include:

• Annual AML compliance report
• Quarterly high-risk relationship reviews
• Ad-hoc reports on material breaches
• Cooperation with regulatory examinations

6.1 Documentation Requirements

The following records are maintained:

6.2 Data Security

All AML records are protected with:

• Role-based access controls
• Audit trails of all access and modifications
• Regular backups and disaster recovery procedures
• Physical and logical security measures
• Compliance with data protection regulations

7.1 Training Program

All personnel receive AML training appropriate to their role:

• Onboarding: Mandatory AML training for all new employees
• Annual Refresher: Updates on regulations and procedures
• Role-Specific: Targeted training for high-risk functions
• Ad-Hoc: Training on emerging risks and typologies

7.2 Training Content

Training covers:

• Money laundering and terrorist financing concepts
• Legal and regulatory requirements
• Company policies and procedures
• Red flag identification
• Reporting obligations and procedures
• Consequences of non-compliance
• Case studies and practical examples

8.1 Three Lines of Defense

8.2 Money Laundering Reporting Officer

The MLRO responsibilities include:

• Receiving and evaluating internal suspicious activity reports
• Filing SARs with the National Crime Agency
• Liaising with law enforcement and regulators
• Maintaining AML policies and procedures
• Overseeing AML training programs
• Reporting to the Board on AML matters

8.3 Board Oversight

The Board of Directors:

• Approves AML policies and risk appetite
• Ensures adequate resources for compliance
• Reviews quarterly AML reports
• Oversees remediation of identified issues
• Sets tone from the top for compliance culture

9.1 Monitoring Program

Regular monitoring includes:

• Daily sanctions screening updates
• Weekly transaction monitoring reports
• Monthly high-risk account reviews
• Quarterly compliance testing
• Annual independent audit
• Periodic regulatory examinations

9.2 Key Performance Indicators

10.1 Compliance Contacts

• Money Laundering Reporting Officer (MLRO)
• The Bitcoin Corporation LTD
• Email: info@thebitcoincorporation.website
• Phone: [Contact via email]

10.2 Regulatory Authorities

• National Crime Agency (NCA) - SAR filing
• Financial Conduct Authority (FCA) - Regulatory compliance
• HM Revenue & Customs - Tax-related matters
• Information Commissioner's Office - Data protection