AML Policy
[Last Updated: October 2023]
This Anti-Money Laundering Policy (hereinafter referred to as "AML Policy", or "Policy") outlines the provisions and predefined procedures after which EasyBit Solutions Inc. (hereinafter referred to as "EasyBit", "We", "Us", or, "Service") is proactively combating unlawful activities and safeguarding our service capabilities from being utilized for laundering funds originating from illegal sources while ensuring compliance with applicable laws and regulations related to AML/KYC, referring to Anti-Money Laundering and Know Your Customer, respectively.

1. AML Measures

We strive to promote security for our partners and clients by actively protecting them from any fraudulent activity and we remain committed to organized efforts aimed at ensuring the highest levels of financial integrity. In this direction, our team has developed a comprehensive and cutting-edge framework of AML Systems and Procedures, collectively referred to as AML Measures.

1.1 AML System

The AML System is an advanced algorithmic risk evaluation and transaction monitoring solution that operates on a risk-based approach, internal blacklisting, and volume-oriented dynamic exchange limits. Our System conducts numerous checks and calculations, considering various criteria, factors, and weighted parameters, to produce a final Risk Score expressed as a percentage. The system was developed by our team and has been improved for many years to the point of demonstrating exceptional performance and efficiency in detecting suspicious transactions and user activities. Further explanation or disclosure of the criteria and parameters contributing to the risk score can not be provided, so as to maintain and ensure the effectiveness of our system. Whenever an order is initiated on our platform and the corresponding deposit is received, our system calculates its Risk Score before processing it and when it surpasses the accepted risk levels may trigger any of the AML Procedures illustrated below.

1.2 AML Procedures

Our AML Procedures encompass a series of actions designed to verify the legitimacy of funds and ensure that the client responsible for them adheres to all legal compliance requirements in accordance with applicable laws and our TOS (Terms of Service). Depending on the specific circumstances, when the risk score of a transaction exceeds any of the predefined thresholds, our system puts the transaction on hold and any of the following actions may be triggered: KYC verification requirements, SOF (Source Of Funds) inquiries, manual case reviews, transaction freezing, transaction reporting, and account restrictions among others that may be conducted per case.

2. Acceptance Warranty

By using our Services, each user warrants the acceptance and agreement with the AML Procedures, which may be applied. As part of such procedures, EasyBit, and our partnered mediating exchange service providers, if any, may request information and documents, aiming, but not limited to, identifying the client, proving the source of the funds, and ascertaining the user’s compliance with our TOS, our partner’s TOS if any, along with any applicable law.

We reserve the right to conduct AML Procedures on an ongoing basis, proactively in case of any occurrence such as a change in the identification documents, and especially when the user activity is considered suspicious or high-risk. A user activity may be deemed suspicious through our AML System and/or at our sole discretion. We reserve the right to request up-to-date documents from any user, even if they have successfully passed an AML Procedure in the past.

During the AML Procedure enforcement, users may be requested to provide us with the following:

  • A high-quality photo of their ID and/or passport, valid in their country;

  • A high-quality photo of the user to evaluate if it matches the document provided in the previous step;

  • Liveness checks, which involve issuing random instructions to ensure that the KYC process is conducted in real time and in accordance with our request;

  • Source of Funds and any other applicable documentation that may be deemed necessary to ascertain that the funds originate from legal sources and the user’s compliance with our TOS (Terms of Service) and applicable laws.

3. Evaluation Process
3.1 Conducting Evaluation

EasyBit reserves the right to appoint third-party service providers certified in relevant procedures, for the purpose of documentation reviewing, ascertaining the authenticity of the provided documents, and carrying out the verification on our behalf. Such a third-party service provider will be ensured to comply with our Privacy Policy and the applicable data protection laws to guarantee the security and confidentiality of users’ personal information.

As soon as we receive the requested documentation, the evaluation process is conducted either programmatically with the assistance of AI software via our third-party verification partners and/or manually depending on the case and in accordance with the AML Procedures that were enforced.

3.2 Data Storage

The provided by the user documentation will be securely stored according to the provisions of the applicable data protection laws and for so long as required by law. Such documents are never disclosed, excluding competent authorities and investigative bodies provisioned in our Privacy Policy, after their relevant official request.

3.3 Positive Result

If the documents and the verification procedure are found to be valid and in line with our TOS and applicable laws, the verification is finalized successfully and the transaction is processed automatically.

3.4 Negative Result

In the event that a user fails to satisfy the AML Procedures requests and/or the user details and account(s) appear to be blacklisted and/or on sanction lists, and/or in violation of our Customer Acceptance Policy or TOS, and/or fails to provide the requested documentation, and/or the provided documents can not be deemed as authentic, EasyBit reserves the right to refuse - stop providing its services to the client, the transaction is not processed, account restriction may occur, and the deposited amount is refunded, however, the client is liable to compensatory charges for any damages EasyBit may suffer in this regard.

In cases where a user is not cooperating with our AML Procedures and we suspect that has also failed to perform them upon our relevant request in the past, and/or, the transaction is suspected of being related to illegal activities, we reserve the right to freeze the transaction and/or transfer the frozen funds to a cold storage wallet for any period of time necessary to complete the investigation and enforce our AML Procedures, and/or report the case to authorities for further investigation and guidance.

4. Limitation of Liabilities

EasyBit takes all necessary actions and measures, uses the best available practices, and the most efficient course of action in order to prevent any fraudulent - illegal activity from occurring. Subsequently, we do not engage in any way and refuse to develop any business relationship, and/or provide our services to any legal entity suspected of money laundering, terrorism financing, corruption, fraud, illegal transfer of assets, drugs, humans, organs, and/or any other illegal trafficking, and/or any other illegal activity. In no event shall EasyBit, the owner, our directors, officers, members, or any kind of employees or agents, be liable or responsible, if our services are being used by any client, for any illegal activity and/or in violation of any applicable law, regardless of if the associated user has passed an enforced AML Procedure, and exempts liability, for any deficiency or error that may arise as a result of human or system error, in identifying any suspicious transaction and/or user activity, and in proactively denying our services to any user suspected of, or associated with, any illegal activity.

If you have any questions related to our AML Policy, feel free to contact our legal department at [email protected].

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