AML CTF Public Statement

1. General information:

UAB "Bentorsa" /Bentorsa/ is a company registered in Lithuania (registry code 306043591), that operates an online crypto currency exchange (crypto to fiat) called Exchange, with the appropriate licenses issued by the European Union. UAB "Bentorsa" via its platform “Exchange” allows its users (individual or corporate) to buy and sell cryptocurrencies for traditional currencies such as the Euro/Dollar.

Bentorsa 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.

Bentorsa 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 Bentorsa service internal policies and aimed at preventing and mitigating possible risks of Bentorsa service being involved in money laundering as well as any other illegal activities.

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

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

Bentorsa 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. Bentorsa OÜ AML/CFT system:

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

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

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

Bentorsa 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 Bentorsa reserves the right to investigate certain Users who have been determined to be risky or suspicious.

Bentorsa 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, Bentorsa 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 Bentorsa Privacy policy and notice and related regulations.

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

To mitigate and minimize the risks and in line with the international requirements, Bentorsa has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which Bentorsa 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.

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, Bentorsa relies on data analysis as a risk-assessment and suspicion detection tool. Bentorsa 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. Bentorsa is entitled to request additional information/data/documents in relation to any transaction and the customer must follow such a request.

Following its AML Policy and procedures and the applicable legal acts, Bentorsa, when necessary, will report to the respective authorities he activities that may be considered as money laundering and terrorist financing. Bentorsa 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)

Bentorsa 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

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

5. Compliance officer:

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

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

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 [email protected]