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Anti-Money Laundering (AML) Policy

1. Introduction

Bullomo (“Company”, “we”, “us”, “our”) is committed to full compliance with all applicable laws and regulations regarding Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and the prevention of illegal financial activity. This AML Policy outlines our procedures and internal controls to detect and prevent the use of our platform for money laundering or terrorist financing.

2. Purpose

The purpose of this policy is to:

  • Prevent the Company from being used for money laundering or terrorist financing.

  • Detect and report suspicious activities in accordance with applicable laws.

  • Protect the integrity of our financial systems and comply with international standards such as FATF recommendations.

3. Scope

This policy applies to all clients, employees, contractors, partners, and service providers of the Company. It covers all activities related to account registration, deposits, withdrawals, and trading in cryptocurrencies and traditional financial instruments.

4. Customer Identification and Verification (KYC)

As part of our AML obligations, we implement a Know Your Customer (KYC) procedure, which includes:

4.1 Individual Clients

  • Full name

  • Date of birth

  • Nationality

  • Valid government-issued photo ID (passport, driver’s license, etc.)

  • Proof of address (utility bill, bank statement no older than 3 months)

4.2 Corporate Clients

  • Company name and registration number

  • Certificate of incorporation

  • Corporate structure and ownership

  • Authorized representatives and UBO (Ultimate Beneficial Owner) identification

  • Proof of business address

We may use third-party identity verification providers to confirm client data.

5. Risk-Based Approach

We apply a risk-based approach (RBA) to AML compliance, which involves:

  • Client risk profiling (low, medium, high)

  • Enhanced Due Diligence (EDD) for high-risk clients (e.g., PEPs, clients from high-risk jurisdictions)

  • Ongoing monitoring of client behavior and transactions

6. Monitoring and Reporting

The Company actively monitors transactions to detect patterns of suspicious behavior, including:

  • Unusual transaction sizes, frequencies, or volumes

  • Use of multiple wallets/accounts

  • Rapid movement of funds with no economic justification

Suspicious activities will be reported to the appropriate regulatory authority or Financial Intelligence Unit (FIU) as required.

7. Transaction Limits

We reserve the right to impose limits on deposits, withdrawals, or trading activity for risk management and AML compliance purposes.

8. Record-Keeping

We retain all identification and transaction records for a minimum of 5 years, or longer if required by applicable law. This includes:

  • KYC documents

  • Transaction history

  • Communication logs related to compliance checks

9. Employee Training

All employees receive periodic AML training, which includes:

  • Recognizing suspicious transactions

  • Reporting procedures

  • Legal responsibilities and consequences of non-compliance

10. Sanctions and Blacklists

We do not conduct business with individuals or entities:

  • Listed on UN, EU, OFAC, or other applicable sanctions lists

  • Operating in jurisdictions classified as high-risk or non-cooperative by FATF

11. Cooperation with Authorities

We fully cooperate with law enforcement and financial regulators in the investigation of money laundering or related criminal activities. We may freeze, block, or close accounts without prior notice if suspicious activity is detected.

12. Policy Review

This AML Policy is reviewed and updated regularly to reflect changes in legal requirements, business operations, or industry best practices.

13. Contact Information

For questions related to this AML Policy, please contact our Compliance Department:

Email: [email protected]