AML and KYC Policy

In terms of law, money laundering refers to legalising the proceeds of crime, i.e. actions that conceal the source of funds in order to make their nature appear lawful.

Anti-money laundering (AML) Policy incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business community.

Financial institutions employ different approaches to anti-money laundering that help preventing cases of laundering of the proceeds of crime and terrorist financing. Under its AML Policy, BitSugar in its operations implements the specific measures listed below.

Our approach

Our Company's organisational structure includes the Head of Risk and Compliance, who is in charge of overseeing compliance of the Company's activities with its internal policies and procedures and relevant AML regulatory enactments.

We trust highly competent personnel of our Company, who works in close contact with our Clients. As part of Internal Regulatory documents, the Company has a Know Your Customer (KYC) Policy in place aimed at full understanding and knowledge of our Clients and Business partners.

The AML Policy of the Company consists, but is not limited to, the following pillars of KYC:

    Ongoing compliance with the requirements introduced by the national and international laws, regulations and sanctions,

    Implementation of the risk-based "KYC" and "Client Monitoring" principles,

    Determination and reporting of suspicious transactions,

    Preservation of reputation and brand value of Immofreund towards national and international authorities.


We improve our AML policy and procedures continuously and they comply with the requirements of Austria law. We make considerable investments in this process and ensure continuous training of our personnel in this area. We understand that anti-money laundering and combating terrorist financing is a continuous process that requires constant attention and ability to monitor unlawful financial schemes.

We comply with the legal requirements of the Republic of Austria for the prevention of money laundering and terrorist financing. 

 We have a strict set of rules in place in order to comply with the AML regulations of the republic of Austria and the International and EU standards:


    All existing Clients are subject to the AML Client monitoring process,

    Identity and proof of address documents and transaction records are maintained for at least five years after the Business relationship has been terminated and will be submitted to regulators accordingly, as required, without prior notification to registered users,

    immofreund may at any time suspend the operation of the Client's account, without liability and without disclosing a reason. The Client is always notified in this case after the Business relationship has been terminated,

    Prospective Clients will be required to verify their identity in line with the Company's KYC policy. This includes submission of both government ID and proof of address. Valid ID includes a passport, national card, or driving license. Valid proof of address includes utility and rates bills not older than 3-6 months, depending on the Client's Risk profile. Other forms of ID will not be accepted.


Accordingly, immofreund performs necessary controls and takes additional measures with respect to:


    Identification and verification of the valid identity and address details of (potential) customers, acceptable to the legal authorities, before establishing a Business relationship and during the course of a continuous Business relation,

    Consistency of the income levels of Clients and the financial services they perform/request with their business, the general course of action and sources of income of the Client type, in which they are included,

    Possibility of the Clients being included on national/international sanctions lists.


immofreund will not be accept the following Persons as Clients under any circumstances:


    Those who cannot provide all the required Client Identification Documents in due course and proper form,

    Those listed under Office of Foreign Assets Control's Special Designated Nationals List (OFAC SDN) watch list and/or United Nation's "Consolidated List",

    Anonymous Clients or those who use fictitious names,

    Those who hold businesses that, due to the nature of the business make it impossible to verify its legitimacy, or hold funds inconsistent with their financial status,

    Those who are suspects, based on reliable information, of being involved in any sort of criminal activities, mainly related to money laundering, drug trafficking, terrorism and organized crime;

    Bearer share companies,

    Shell companies,

    Those who raise any legitimate suspicions by the Company's staff and/or the Head of Compliance. 


Governmental (OFAC) restrictions, international sanctions and our Internal Policies prohibit us from opening accounts for individuals from the following countries: Afghanistan, Algeria, Angola, Burundi, Central African Republic, Congo Republic, Democratic Republic of Congo, Ecuador, Eritrea, Ethiopia, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Kenya, Lebanon, Liberia, Libya, Myanmar, Nigeria, North Korea, Serbia, Somalia, South Sudan, Sudan, Syria, Trinidad and Tobago, Tunisia, USA, Vanuatu, Venezuela, Western Sahara, Yemen, and Zimbabwe, as well as other individuals specifically sanctioned. 

Thursday, August 22, 2019

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