Privacy Policy

Know Your Customer, Anti-Money Laundering & Surveillance Policy

INTRODUCTION

Effective quarter 1 of 2020, Singapore will put in place a new regulatory framework pertaining to the Digital Banking License and Payment Services Act, which will govern the growing number of Fintech Service Providers in Singapore.

All fintech companies are required to comply with the Payment Services Act, issued by the Monetary Authority of Singapore (MAS), to acquire the necessary licenses to continue to provide financial related service in Singapore and as per Payment Service Act and other regulatory platforms in Singapore, Cryptocurrencies will be classified as Digital Payment Tokens (DPT).

As of 28 January 2020, the Payment Services Act will be officially put in place and all persons conducting activities under the Payment Services Act, will have to obtain a license to conduct business in Singapore. Such businesses that will be affected by the Payment Service Act include account issuance, domestic money transfers, cross-border money transfers, merchant acquisition, e-money issuance, digital payment tokens, and money changing.

For all its intent and purpose, the Payment Services Act seeks to protect users’ interests, by mandating the safeguarding of funds in transit and e-money float to ensure user protection. While it will require some payment service providers to implement safeguarding measures, Digital Payment Token (DPT) investments will not be covered with this release of the Payment Services Act. Instead, regulators in Singapore will continue to monitor trends and risks in the use of DPTs in Singapore, and further develop the Payment Services Act for conduciveness for all parties.

AML-CFT: AML-CFT refers to Anti-Money Laundering and Counter Financing of Terrorism, which are internationally practised measures, set to deter criminals from abusing the financial system.

Due to the anonymous nature of Digital Payment Token (DPT) and cryptocurrency transactions, Anti-Money Laundering/ Counter Financing of Terrorism (AML-CFT) measures will come into place with the Payment Services Act, to mitigate such risks in Singapore; Digital Payment Tokens (DPT) providers or businesses providing custodian wallets will be expected to comply with the AML-CFT standards of the Payment Services Act.

KYC/AML PHILOSOPHY OF Bxmi

Bxmi Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is created to prevent and mitigate possible risks of Bxmi being caught in any sort of activities that are deemed as illegal.

Regulators internationally and locally have set up rules & regulations that require Bxmi to put in place effective internal procedures and mechanisms to facilitate any sort of money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity that may arise from its Users.

The KYC/AML philosophy of Bxmi is to prevent the company from being complicit to any such activities either intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities. The sole purpose of this policy is also to help Bxmi better understand its customers and their dealing. This way, Bxmi can better manage its risk and deal with potential pitfalls more effectively.

Overall, Bxmi cannot stressed enough, the importance of having its management take the issue of “money-laundering prevention” and “knowing your customer” seriously. These two areas also formed part of its risk management strategies and not simply as stand- alone requirements that are being imposed by legislation/regulators’.

For Bxmi, the objective of the policy primarily covers the following: -

1. To incorporate a comprehensive Customer Due Diligence (CDD) process before clients are being registered.

1. To ensure records pertaining to cash transactions are monitored and maintained properly

1. To maintain records of all series of integrally connected cash transactions within one calendar month.

1. To monitor any sort of suspicious transactions and to report them to the authorities as soon as possible

1. To setup guidelines to discourage the usage of our platform for any sort of money laundering and terrorist financing activities

1. To take adequate and appropriate measures to follow new guidelines that maybe implemented by MAS

WHAT IS ANTI-MONEY LAUNDERING (AML)

Anti-money laundering (AML) is a broad term for laws and regulations put in place to prevent criminals from making money illegally or moving illicit funds. AML laws target a wide variety of illegal activities and some of its most important are those that include tax evasion, public corruption, and market manipulation through methods such as wash trading.

Owing to the complexity of the relevant laws, many financial institutions use AML software to detect questionable activity. Such software can perform functions such as checking customer names against a host of prohibited users in the government list to creating records that are essential for compliance maintenance.

AML is tightly linked to Know Your Customer (KYC) requirements, which entail checking customers’ identities and sources of their income. KYC also requires financial institutions to monitor their users' activity on an ongoing basis. Like AML, KYC checking procedures are highly automated and most financial institutions would use the onboarding process of new clients to get information relating to the necessary checks.

In the cryptocurrency arena, AML programs are also hugely relevant. Many cryptocurrency exchanges have mounted huge efforts to deal with anti-money laundering laws as regulators start to place more focus on the cryptocurrency market. With mounting efforts to apply KYC and AML requirements within the crypto space, many are critical of a loss of privacy in the quest of compliance alignment. The many benefits attributed to decentralisation is now nulled and void when one start placing sensitive personal data in centralized databases. However, proponents of more central governance still argue that solutions can be devised that will meet regulatory requirements while still ensuring user privacy.

One interesting trend relating to AML and KYC compliance in the cryptocurrency ecosystem is the willingness of many exchanges to self-regulate, even when they do not fall within the purview of existing regulatory guidelines. In some cases, companies have even banded together to form industry bodies aimed at creating frameworks for self-regulation. This kind of voluntary compliance both minimizes future legal risks for the crypto-related businesses and improves the likelihood of wider adoption of cryptocurrency

WHY KNOW YOUR CUSTOMER (KYC)

KYC is a process that is used to gather identifying data and contact information from soon to be customers. This process is mainly used by banks and other financial institutions to sift out the potential of fraud, money laundering and other illicit activities. It is also a way to prevent clients from misusing their financial accounts.

KYC practices usually start before an individual becomes a customer. Financial institutions must first verify the stated identity of a potential customer before opening an account. Because there are no legal verification standards, this process may look different for each bank.

Some identifying documents required by KYC processes include:

Driver’s License / Government-issued photo ID

Passport

Address verification is also crucial. Applicants may submit different documentary proof, depending on the bank’s practices. Some financial institutions are willing to accept utility bills, account statements from a different bank or credit card issuer or even lease agreements.

Once an account is setup for the customer, banks are required to carry out periodic record updates. This means they continue to “recertify” their customers with intermittent requests for KYC information throughout their banking relationship. They also assign a risk level to their customers and monitor customer transactions to ensure they match expected behaviour.

Practices in KYC are not just carried out by banks. The financial investment industry uses KYC processes in compliance with the Financial Industry Regulatory Authority (FINRA) KYC Rule 2090. But rather than an AML effort, these KYC practices help investment companies better understand client needs.

When it comes to cryptocurrency exchanges, users are often able to create an account before concluding the KYC process. However, these non-verified accounts present limited functionalities. CONTENT OF AML/KYC Policy

In line with best practices in the industry, Bxmi has put in place, strict policies that will keep the company in compliance with international AMK/KYC policies. Processes that the company actively employ include: -

1. Various Verification Procedures.

1. Sanctions and PEP lists screening.

1. Employment of Compliance Officers to ensure rules & regulations are abided with

1. Monitoring Transactions.

1. Regular Risk Assessment.

1. Verification procedures

Bxmi employs the customer due diligence (CDD) international standard as its golden rule for the prevention of illegal activities. According to CDD, Bxmi establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification

Using an identity verification procedure, Bxmi requires all Users to provide the platform with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). The company reserves its right to collate and collect such information for the purpose of fulfilling its AML/KYC compliance.

Bxmi will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Bxmi reserves the right to investigate certain Users who have been determined to be risky or suspicious.

The company reserves the right to engage in ongoing verification of a User’s identity. This is most important when there are changes to a User’s identification and when Users are suspected of illegal activity. Bxmi also reserves the right to request for a User’s latest up to date document for verification, although the User may have passed all verification processes in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with Bxmi’s Privacy Policy and related regulations.

Once the User’s identity has been verified, Bxmi is then able to remove itself from potential legal liability if an occasion arise whereby its platform is being utilised to conduct illegal dealings.

2. Sanctions and PEP lists screening.

Bxmi screens all potential customers against a list of known Sanctions and Politically Exposed Persons (PEPs). Both individuals as well as all legal entities will be screened against such a list at the onboarding stage when an application is being submitted by an individual.

When an alert pertaining to anti-fraud and AML is flagged by a Compliance Officer, potential customers will also be screened through the list.

Ongoing automatic monthly checks will also subject all customers to such a screening to avoid any potential change in the status of a client.

Bxmi performs the screening process using the World Compliance data (provided by Accuity) integrated into its proprietary software and supported by World-Check One online search tool for manual confirmation.

1. Sanctions coverage as per FINMA and MAS requirements including OFAC, EU, HMT, UN etc

2. 2.1 million PEP individuals and over 400,000 State Owned Entities (Data in association with LexisNexis)

3. Coverage of 35,000+ Adverse Media covering money laundering, financial crimes, corruption, weapons, drugs amongst others)

4. Information includes detailed pictures, associated entities, subsidiaries etc

5. Option to have API integration, batch uploads

6. Ongoing monitoring to ensure platform users are flagged automatically when risky

7. Use passport verification tool to check authenticity of passport globally

3. Compliance Officer

Bxmi has put in place, Compliance Officers, which is duly authorized by Bxmi, to ensure the effective implementation and enforcement of the AML/KYC Policy. The duty of the Compliance Officer is to supervise all aspects of Bxmi’s anti-money laundering and counter-terrorist financing, including but not limited to:

1. Collecting Users’ identification information.

1. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.

1. Monitoring transactions and investigating any significant deviations from normal activity.

1. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.

1. Updating risk assessment regularly.

1. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer will be tasked to correspond with law enforcement in the area of prevention of money laundering, terrorist financing and other illegal activity.

4. Monitoring Transactions

Bxmi will carry out constant verification of User’s identity throughout their stay as an existing customer. Transactional patterns of ongoing customers will be subjected to regular data analysis as a risk assessment and suspicious detection tool. Bxmi platform and compliance tool will perform a variety of compliance-related tasks, including data capturing, filtering, record-keeping, investigation management, and reporting.

In the nutshell, our system’s functionalities will encompass:

1) Checking our Users daily against a known “blacklist” (e.g. OFAC), aggregating transfers by multiple data points, putting suspicious Users on watch and service denial lists, where there are unknown factors, we will carry out the appropriate investigation opening cases for investigation and sending internal communications and filling out statutory reports, if the need arises;

2) Case and document management.

To further strengthen our AML/KYC Policy, Bxmi will monitor all transactions and it will reserve the right to:

• The Compliance Officer will ensure that transactions of suspicious nature are reported to the proper law enforcement;

• Should Bxmi suspect any wrongdoing or suspicious transaction on the part of the User, additional information and documents will be requested from the User;

• In unusually alarming situation, Bxmi will either suspend or terminate User’s Account;

The above list is, however, not exhaustive of what Bxmi will do and the Compliance Officer is tasked to monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

5. Risk Assessment

There are essentially four main areas of risk that Bxmi seeks to regulate on a daily basis.

Dispersed Risk:

Spreading risk is a widely accepted way to succeed in the financial market. But the complex way in which certain risks are dispersed across anonymous networks or computers in a crypto exchange makes is difficult to pinpoint the exact source of a threat or risk in the system.

Anonymity:

The anonymous, digital nature of cryptocurrency transactions means there is a natural lack of control and physical security. This allows new opportunities for someone with malicious intent.

Lack of Control:

Typically, network administrators and advanced computer engineers can develop robust controls to ensure the cryptocurrency is able to be stored and used as appropriate. But what happens if the device is stored on a thumb drive and is stolen or damaged? What happens if someone performs a tiger kidnap and forces transactions to take place?

Potential for Significant Loss:

Unlike in a vault robbery where millions of dollars in bulky and heavy currency takes multiple trips to remove from a vault, the same amount can be removed in seconds with a thumb drive into an anonymous sea of computers.

For better risk assessment, Bxmi, in accordance to international requirements, has adopted a risk-based approach to combating money laundering and terrorist. This approach will enable Bxmi to prevent or mitigate money laundering and terrorist financing and to commensurate its efforts to the identified risks. Resources can then be allocated in the most efficient way with the greatest risks receiving the highest priority.

Privacy Statement

Bxmi.General Risk Disclosure

This notice is intended to inform you of the risks that are generally associated with investment products. Bxmi provides a diverse range of investment products as well as instruments and features related to trading so we suggest studying this section to learn about potential pitfalls:

• ● Appropriateness. We regularly evaluate the products and services provided to our users based on their feedback. If the chosen investment products aren t suitable for traders, we warn them and notify about risks. Users are still eligible to agree with these risks and proceed with the chosen assets.

• ● Software. Various third-party applications utilize different protocols and APIs. We aren t responsible for any errors related to these protocols, software security, and accessibility. Moreover, we may suspend trading operations with a given software protocol or restrict trading from certain accounts in case of problems.

• ● Third parties. Apart from external software, our exchange can cooperate with third-party platforms to execute orders or keep fiat money. These partners aren t responsible for your losses even if they are officially registered. Thus, we also don t cover these damages related to problems with external storages or processors.

• ● Internet System errors, software/hardware failures, disconnections, hacker attacks, and malware can affect your trading and lead to delays or issues with order placements. Be aware of this fact and also remember that SMS and email services are vulnerable to attacks. Always check emails to see if they are from our team.

• ● Fee All our charges are listed at the official website. Review them carefully to be sure that fee are suitable for you as they can affect the trading s profitability.

• ● Information. Any news, opinions, research, analysis or any other information is shared here as general commentaries and doesn t act as trading suggestions.

• ● Past performance. The value of future investments can t be determined by past transactions. Your performance can lead to either losses or profits at any time.

• Crypto Trading Risks

• When it comes to the essence of crypto trading, users should clearly realize a few more points and associated risks. Services of Bxmi aren t regulated by any authorities as well as crypto

markets are unregulated and decentralized by their nature. Means, in case of any issues, there will be no official bodies to interfere or react.
Generally, cryptocurrency trading markets are based on users demand and supply. Prices of coins are hardly predictable and highly volatile. Users can experience upside and downside risks and Bxmi doesn t guarantee the profitability of any asset or deal. You always should understand the principles of crypto trading and price formation. Crypto trading is also related to risks of fraudulent and illegal activities as this market isn t regulated and all deals are executed anonymously, actually. At all, crypto coins are high-risk assets so you want to invest only the amount you can afford to lose. It s possible to end up with losing everything you have invested initially. Apart from the mentioned things, remember about:

• ● Execution. It happens that prices of assets change during the pending period between

• the order placement and its execution. These changes can be either profitable or unprofitable but users can protect positions by using Stop Loss orders. Still, this features isn't always effective because of market volatility.

• ● Position monitoring. It should be clear that the monitoring of open positions is the full responsibility of traders. Bxmi can spectate for activity related to your trading but we will not notify you about losses/profits or required changes.

• ● Delisting. It is possible that the cryptocurrencies involved in your order are delisted or unsupported by the exchange platform with time. The order will be shut down then. We will try to sell assets that will be delisted on your behalf to minimize losses.

• ● Currencies. Traders accounts at Bxmi are open in USD. You should spectate for all price fluctuations and rate changes if you deposit money in another currency. Be sure to look at cross rates between fiat currencies and crypto, as well.

• ● Blockchain. Finally, you should remember about risks related to blockchain systems. All the coins are based on decentralized platforms that also can face policy changes or tech problems. We aren 't responsible for them and their consequences.

*CRYPTOCURRENCY MARKETS ARE DETERMINED BY DEMAND AND SUPPLY ONLY

The world of cryptocurrencies is full of fluctuations, and changes as the cryptocurrencies market are never stable. The prices are often unpredictable and volatile, and the winds can blow either in your favor or against your interests. The worst outcome for a trader could be that his / her product is left useless.

The difference between the prices on the charts (the indicative prices) and the deal able prices should be known to traders. It must be understood that these prices often differ as the indicative prices are only a reflection of the deal able prices, giving an approximate idea of where the market stands in terms of prices. For the most accurate prices in trading, the deal able prices must be viewed by the clients as trades can only be executed on these prices.

Cryptocurrency trading, like many other businesses, is susceptible to many illegal activities and transactions as the transactions and trades are executed anonymously. It must be understood that there is a risk that trading practices could be affected adversely if the law enforcement authorities decide to investigate any allegations made.

CRYPTOCURRENCIES ARE ASSETS THAT ARE EXTREMELY HIGH-RISK, AND FUNDS THAT ONE CANNOT AFFORD TO LOSE SHOULD NEVER BE INVESTED

It must be known to all potential investors that cryptocurrencies trading is very volatile and unpredictable. It is a very high-risk investment, and you should not invest any amount that you cannot afford to lose. Moreover, Bxmi spread itself has been added to online quotes which confirms just how unpredictable cryptocurrencies trading can be.

It must be known to all potential investors that cryptocurrencies trading is very volatile and unpredictable. It is a very high-risk investment, and you should not invest any amount that you cannot afford to lose. Moreover, Bxmi spread itself has been added to online quotes which confirms just how unpredictable cryptocurrencies trading can be.

Trading over the weekends is allowed for by Bxmi, but we reserve the right to withdraw this allowance. In the case that this allowance is withdrawn, there is a possibility that there could be a considerable difference between Friday closings and Sunday openings. This could lead to a scenario where either you can 't complete your order on a particular day or that you might have to do so on a less reasonable price.

Certain market conditions can make it difficult, or sometimes even impossible to liquidate a position. This is a possibility in the condition when the market climbs to a daily price fluctuation limit.

The blockchain network involves certain risks as well. However, unfortunately, this independent peer to peer network is not managed or controlled by Bxmi in any manner. Hence, you will be held to any changes in the blockchain system which can include taking measures that are not necessarily in your favor. We at Bxmi take no responsibility for any changes in blockchain policies and alterations.

OPERATION OF CRYPTOCURRENCY PROTOCOLS

The software protocols used are open source and can be used, copied, and modified by anyone. Bxmi is not liable for any of these software protocols and their security and availability. Unanticipated operating rules, also known as forks, are known to affect the function and value of your cryptocurrencies. If a fork occurs, Bxmi may have to suspend trading operations across its platform as well as configure or reconfigure its systems and decide not to support the protocol. What 's more, Bxmi may have to make some changes and alterations in your account in such a case.

THIRD PARTIES ' RISKS

Orders can be executed, and fiat money can be held by Bxmi through third parties in some cases. These third parties do not constitute banks and any losses against you are not legally protected to cover you even if the third party is registered with any of the authorities. Customer assets can be lost in such cases, and it must be clarified that ABC will not be responsible for any losses in these cases.

It is possible that the cryptocurrencies involved in your order are delisted or unsupported by Bxmi with time. In this case, your application order will be shut down at once. If we are notified that any cryptocurrency in your account is likely to be delisted, we will make an effort to sell the cryptocurrencies on your behalf to minimize loss.

AUTOMATED TRADING AND INTERNET RISKS

System errors and system failures are problems that can arise and can lead to delay or failure of order placement. It must be understood that your trading practices can be affected by problems such as failure of hardware and/or software, internet disconnection, the risk of third parties gaining unauthorized access to your information, software viruses, cyber-attack, cryptocurrency network failure, communication failures, errors, disruptions, and delays, etc. What 's more, malware such as spyware and Trojan horses can cause damage to your computer or other devices as well. It should also be noted that SMS and email services are prone to attacks as well and you should be cautious when checking your messages to see if they are from us.

FEE AND COSTS

Our charges regarding every service are listed on our website. Review them carefully and understand that all fee apply to you as this affects your profitability.

INFORMATION

Any news, opinions, research, analyses or any other information shared here serves as general market commentary and does not constitute advice in any manner. It must be understood that Bxmi will be liable for any losses sustained by its traders or for any unstable conditions in the market.

PAST PERFORMANCE

The value of future investments cannot be determined by an evaluation of past performances. Your performance can lead to either losses or profits, regardless of how you might have fared in the cryptocurrencies trading world.

CURRENCY RISK

Your account with Bxmi will be held in USD. You must keep track of any fluctuations in currency if the currency of your deposit is different from this.

Anti-Money Laundering/Counter the Financing of Terrorism (AML/CFT) KYC Policy
The Bxmi Pte. Ltd Policy is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML/ KYC Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance

• Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company

• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs)

• Establishing and maintaining risk based systems and procedures to monitor on-going customer activity

• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate

• The maintenance of appropriate records for the minimum prescribed periods

• Training and awareness for all relevant employees

Counter Financing of Terrorism (CFT)

The Company takes a risk-based approach when adopting and implementing counter financing of terrorism (CFT) measures and in conducting AML risk assessments.

The company adopted internal CFT controls and make undefended decisions regarding CFT matters supersedes any business, strategic or other operating task.

International Sanctions Policy (ISP)

Our company is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists.

Know Your Customer Procedures (KYC)

Individuals can be identified by passport or other identification document and utility bills stating their current post address with selfie with a code sent via verified mail. Companies have to be identified by extracts from the Chamber of Commerce or by notary deed. Copies have to be made and archived in files securely.