ANTI-MONEY LAUNDERING POLICY OF
Blockchain International Corporate Registry Authority
1.Policy Statement and Purposes of this Policy
1.1. BlockchainTrust takes a zero-tolerance approach to money laundering and terrorist financing activities and is committed to implementing and enforcing effective internal controls to counter such activities.
1.2. BlockchainTrust’s policy is to apply at a minimum the standards set out in this Policy.
1.3. The purpose of this Policy is to:
(a) set out the responsibilities of BlockchainTrust and its trustees, advisors and all staff working for BlockchainTrust, whether on a paid or voluntary basis (together “BlockchainTrust Individuals”), in respect of observing, complying with, and upholding policies on anti-money laundering (“AML”) and counter-terrorist financing (“CTF”); and
(b) provide information and guidance to BlockchainTrust Individuals on the money laundering/terrorist financing risks arising in relation to BlockchainTrust’s activities, BlockchainTrust’s due diligence procedures, and how to recognise and deal with any potential money laundering/terrorist financing issues if they arise.
1.4. This Policy may be amended from time to time to reflect updates to the laws and regulations on which it is based.
2. Application of this Policy
This Policy applies to all BlockchainTrust Individuals, including those working with BlockchainTrust on a purely voluntary basis. BlockchainTrust will terminate its involvement with any BlockchainTrust Individuals who fail to comply with this Policy.
3. Money Laundering and Terrorist Financing
3.1. Money Laundering (“ML”)
(a) Under international law, the term “money laundering” refers to an act intended to have the effect of making any “property” (defined broadly to include any tangible or intangible financial benefit) that represents the proceeds obtained from the commission of a crime appear not to represent such proceeds. Put another way, money laundering is the process of disguising or “cleaning” money directly or indirectly arising from criminal activity (i.e. “dirty money”) so as to conceal its criminal origins.
(b) The criminal activity in question must either be (a) an “indictable offence” under international laws, or (b) any conduct which, if it had occurred in any jurisdiction, which would constitute an indictable offence under the laws of that jurisdiction.
(c) ML generally consists of three common stages:
(i) placement - the physical disposal of cash proceeds derived from illegal activities into the financial system, or conversion of funds already in the financial system into the proceeds of crime (e.g. payments made for corrupt or criminal purposes);
(ii) layering - separating illicit proceeds from their source by creating complex layers of financial transactions, often with no legitimate commercial purpose, designed to disguise the source of the money, subvert the audit trail and provide anonymity; and
(iii) integration - returning the laundered proceeds back into the general financial system in a way so that they appear to be the result of, or connected to, legitimate business activities.
(d) The primary ML offences under international criminal law are set out in the UN Model Provisions on Money Laundering, Terrorist Financing, Preventive Measures and Proceeds of Crime (together, the “ML Statutes”).
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