(AML) POLICY
Hash Pay Sp. z o.o., a company duly incorporated in Poland with registered company number KRS 0001142777 and registered office address at UL. Stanisława Przybyszewskiego 91-99, m. 15, 93-126, ŁÓDŹ, POLSKA (“BetterHash”, “us”, “we”, or “our”).
Virtual currencies constitute the primary business area of BetterHash and represent one of the most dynamic, rapidly evolving, and innovative sectors in today’s financial services realm.
BetterHash is committed to identifying, preventing, and mitigating risks associated with money laundering and the financing of criminal activities. We have established a comprehensive system of internal rules and measures that comply with all applicable requirements set under the following regulations:
– Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (Journal of Laws of 2018, item 723);
– Regulation of the Minister of Finance of 22 December 2019 on the types of documents confirming the identity of the customer and the manner of obtaining them (Journal of Laws of 2019, item 2532);
– Act No. 69/2006 Coll. on the Implementation of International Sanctions;
– Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering;
– Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012;
– Regulation (EU) No 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006;
– Criminal Code of the Republic of Poland (Journal of Laws of 1997, No. 88, item 553).
In simplified terms, money laundering refers to activities where a customer uses the services of BetterHash to disguise the illegal origins of their property or to make tracking more difficult. Similar rules apply to other businesses in Poland and beyond, as money laundering is often conducted internationally.
1. Core Principles
1.1. To prevent the misuse of BetterHash’s platform for illegal purposes such as money laundering or the funding of criminal activities.
1.2. To apply risk-based internal controls tailored to the specific nature and risks of crypto asset activities.
1.3. To comply fully with applicable domestic and international AML regulations.
2. Know Your Customer (KYC) and Customer Due Diligence (CDD)
2.1. BetterHash provides its services only to customers who have successfully completed the Know Your Customer (KYC) process.
2.2. As part of our onboarding process, we collect and verify:
– Full name (including any former names);
– Residential address (including country, postal code, city);
– Date of birth;
– Citizenship;
– Email address and phone number.
2.3. Identification documents we typically request include:
– A valid government-issued ID (passport or national ID with MRZ);
– Proof of address (e.g., utility bill or bank statement);
– Any additional documents to clarify source of funds, occupation, or transaction purpose.
2.4. The KYC process is facilitated by Sumsub, our trusted third-party provider for electronic identification and document verification. Sumsub ensures a thorough verification process to meet our AML obligations effectively.
3. Risk-Based Approach
3.1. BetterHash applies a risk-based approach (RBA) to AML. This includes ongoing customer risk profiling and transaction behavior analysis.
3.2. Customers are assigned a risk rating (low, medium, or high) which may change over time.
3.3. High-risk customers are subject to Enhanced Due Diligence (EDD), which may include:
– Additional document requests;
– Verification of source of funds;
– Enhanced transaction monitoring.
4. Sanctions and Screening
4.1. We screen all potential and existing users against multiple sanctions lists, including:
– United Nations (UN);
– European Union (EU);
– Office of Foreign Assets Control (OFAC);
– Politically Exposed Persons (PEP) databases;
– Other international watchlists.
4.2. BetterHash will not establish or maintain business relationships with individuals or entities located in or associated with sanctioned or high-risk jurisdictions, including:
– Afghanistan
– Bahamas
– Barbados
– Botswana
– Cambodia
– Crimea
– Cuba
– Democratic People’s Republic of Korea (DPRK)
– Ghana
– Iran
– Iraq
– Jamaica
– Lebanon
– Libya
– Mauritius
– Myanmar/Burma
– Nicaragua
– Pakistan
– Panama
– Russian Federation
– Syria
– Trinidad and Tobago
– Uganda
– United States of America
– Vanuatu
– Venezuela
– West Bank and Gaza Strip
– Yemen
– Zimbabwe
– Belarus
5. Ongoing Monitoring and Reporting
5.1. We continuously monitor user activity for suspicious or unusual patterns.
5.2. Any detected suspicious activity is reported promptly to the relevant Financial Intelligence Unit (FIU) in Poland.
5.3. Transaction limits may be placed based on user risk level, transaction history, and other internal assessments.
6. Record-Keeping
6.1. We retain identification documents, transaction records, communications, and compliance-related documentation for a minimum period of 5 years after the termination of the business relationship.
7. Customer Obligations
7.1. Customers must:
– Provide accurate and complete information;
– Submit all required documents in a timely manner;
– Notify us of any changes in personal information or status.
7.2. Failure to comply with KYC requirements may result in:
– Refusal to establish a business relationship;
– Blocking or termination of the customer account;
– Reporting to the Polish authorities.
8. Staff Training
8.1. Our employees receive ongoing training in AML principles, red flags, suspicious activity detection, and legal obligations.
8.2. The training is mandatory and reviewed annually.
9. Policy Revisions
9.1. We reserve the right to update this AML Policy at any time to reflect changes in regulations or operational practices.
9.2. Any material amendments will be communicated through our platform. Customers are responsible for staying informed of the latest version.
10. Contact Information
For questions about this policy or to report suspicious activity, contact:
Compliance Department – Hash Pay Sp. z o.o.
UL. Stanisława Przybyszewskiego 91-99, m. 15
93-126, Łódź, Poland
Email: [email protected]
By using BetterHash.io, you confirm your understanding and agreement with this AML Policy.