0.1. Biza Pty Ltd (“Biza”) has an obligation under Australian law to take appropriate action to ensure it is not involved in the facilitation of money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery.
0.2. Therefore, the Biza Pty Ltd Anti-Money Laundering and Know Your Customer Policy (“AML/KYC Policy”) has been designed to ensure compliance with this obligations and mitigate risks Biza may face in relation to any kind of illegal activity.
This AML/KYC Policy covers the following relevant areas:
- Verification procedures.
- Compliance Officer.
- Monitoring Transactions.
1. Identity verification procedures
1.1. The Australian Transaction Reports and Analysis Centre (AUSTRAC) requires that all businesses operating as a digital currency exchange provider establish strong identity verification procedures. In order to efficiently deliver on this objective Biza restricts account registrations to Australian passport holders and utilises the services of Digital ID, an Australia Post (“Auspost”) subsidiary, to conduct the identity verification process.
1.3. Biza does not allow users to gain access to our services without this identity verification process taking place.
2. Compliance Officer
2.1. AUSTRAC requires all reporting entities to register an AML/CTF compliance officer (“Compliance Officer”), whose duty is to ensure effective implementation and delivery of a reporting entities legal obligations with regards to AML & KYC. The Compliance Officer, duly appointed by Biza, has a responsibility to supervise all aspects of Biza’s anti-money laundering & counter-terrorism financing obligations, including but not limited to:
- ensuring continued compliance with the requirements of the AML/CTF Act and AML/CTF Rules and subject to the ongoing oversight of the reporting entity’s board and senior management
- day-to-day oversight of the AML/CTF program
- regular reporting, including reporting of non-compliance, to the board and senior management
- addressing any AUSTRAC feedback about the reporting entity’s risk management performance or AML/CTF program
- acting as the AUSTRAC contact officer for matters such as reporting suspicious matters, international funds transfer instructions and threshold transactions, urgent reporting, compliance audits, or requests for information or documents
- contributing to designing, implementing and maintaining internal AML/CTF compliance manuals, policies, procedures and systems.
2.2. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
3.1. 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, Biza relies on data analysis as a risk-assessment and unusual transaction detection tool. Biza performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.
3.2. System functionalities include:
- Regular checking of users against Australian government sanction lists
- Identification of Politically Exposed Person’s for enhanced risk monitoring
- Threshold transaction reporting to meet our AUSTRAC obligations
- A Risk Management framework as defined by AUSTRAC guidelines
3.3. With regard to the AML/KYC Policy, Biza monitors all transactions and reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when Biza has reasonably suspicion that such User engaged in illegal activity.
3.4. The above list is not exhaustive and the Compliance Officer will 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.