AML CTF Public Statement

1. General information:

Coin Base OÜ /Coin Base/ is a company registered in Estonia (registry code 14718623), that operates an online crypto currency exchange (crypto to fiat) called Coin Base, with the appropriate licenses issued by the European Union. Coin Base OÜ via its platform “Coin Base” allows its users (individual or corporate) to buy and sell cryptocurrencies for traditional currencies such as the Euro/Dollar.

Virtual Currency Wallet Service FRK000807
Exchange of cryptocurrency to Fiat Currency FVR000913

Coin Base strives to protect our Users from fraudulent and scam activities in the crypto assets sphere. It is possible, that certain crypto assets are used for scam or any other criminal activity, as defined by law. In order to prevent this, it is necessary to take measures to ensure customer verification and security of financial transactions. One of the important measures is AML/KYC procedure, which allows us to confirm, that you are a law-abiding individual or corporation. For security reasons, we are not able to disclose specific criteria of our system, however, it has proven to be very effective against money launderers, scammers etc.

Coin Base service reserves the right to apply the AML/KYC procedure to certain Users, addresses and particular transactions of crypto assets. Application of the AML/KYC procedure is based on Coin Base service internal policies and aimed at preventing and mitigating possible risks of Coin Base service being involved in money laundering as well as any other illegal activities.

Please be informed that Coin Base service reserves the right to appoint a Third-party service provider in order to fulfil AML/KYC procedure on behalf of Coin Base service. While processing your information, such service provider fully complies with our Privacy Policy in regards to your personal information.

Coin Base service may forward the information collected during AML/KYC procedure to the competent authorities upon legitimate request.

Coin Base service will not enter a business arrangement with any individual or entity suspected of or directly involved in money laundering, or in which the funds have been the source of illegal activity.

2. Coin Base OÜ AML/CFT system:

The Coin Base AML system is designated to prevent and mitigate possible AML/CFT risks of Coin Base being involved in any kind of illegal activity.

To minimize and mitigate the risk of money laundering and/or terrorist financing, Coin Base has implemented effective internal measures and procedures:

Identification and verification /Know Your Customer/

Coin Base identity and verification procedure requires Users to provide Coin Base with reliable, independent source documents, data or information (e.g. national ID, international passport, bank statement, utility bill). Coin Base reserves the right to collect Users’ identification information for AML/KYC Policy purposes.

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

Coin Base reserves the right to verify Users’ identity on an on-going basis, especially when their identification information has been changed or their activity seems suspicious. In addition, Coin Base reserves the right to request up-to-date documents from Users, even though they have passed identity verification in the past.

Users’ identification information will be collected, stored, shared and protected strictly in accordance with Coin Base Privacy policy and notice and related regulations.

Once the User’s identity has been verified, Coin Base is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.

AML/CFT risk assessment

To mitigate and minimize the risks and in line with the international requirements, Coin Base has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which Coin Base is exposed, and take the appropriate mitigation measures in accordance with the level of risk. A risk-based approach also allows to pay most of the attention to higher risks and allocate most of the resources for mitigation of such risks.

Monitoring of customer’s activities and transactions;

The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Coin Base relies on data analysis as a risk-assessment and suspicion detection tool. Coin Base performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures will be taken to ensure no money laundering or terrorist financing activity is performed. Coin Base is entitled to request additional information/data/documents in relation to any transaction and the customer must follow such a request.

Reporting of suspicious activities to respective authorities.

Following its AML Policy and procedures and the applicable legal acts, Coin Base, when necessary, will report to the respective authorities he activities that may be considered as money laundering and terrorist financing. Coin Base will not disclose any information about such report to have been made and will not address any questions in relation to that.

Counter Financing of Terrorism (CFT)

Coin Base takes a risk-based approach when adopting and implementing counter financing of terrorism (CFT) measures and in conducting AML risk assessments. The company has adopted internal CFT controls and makes undefended decisions regarding CFT matters which supersedes any business, strategic or other operating task.

4. Sanction policy

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

5. Compliance officer:

Coin Base has appointed a Compliance officer that meets the AML/CFT law requirements.

The Compliance Officer is duly authorized by Coin Base to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Coin Base anti- money laundering and counter-terrorism financing, including but not limited to:

Reporting of suspicious activities to respective authorities.
Collecting Users’ identification information.
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.
Monitoring transactions and investigating any significant deviations from normal client’s activity.
Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
Updating risk assessment regularly.
Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved in the prevention of money laundering, terrorism financing and other illegal activity.

6. Contact information:

If you have any questions about the AML/KYC procedure, please contact us via compliance@bblink.io