Barginex AML and KYC Policy is designated to prevent and mitigate possible risks of Barginex being involved in any kind of illegal and suspicious activity.

Restricted Countries

Please keep in mind that we do not currently serve people from: Burma, Cuba, Democratic Republic of Congo, Iran, Iraq, Ivory Coast, Liberia, North Korea, Sudan, Syria, United States of America, and Zimbabwe.

AML/KYC Policy Covers the Following Matters:

Verification procedures.

Compliance Officer.

Monitoring Transactions.

Risk Assessment.

1.Verification Procedures

One of the international standards for preventing illegal activity is customer due diligence (referred to “CDD”). According to CDD, Barginex establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

1.1. Identity verification

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

Barginex will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Barginex reserves the right to investigate certain Users who have been determined as risky or suspicious.

Barginex reserves the right to verify User’s identity at any time, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Barginex reserves the right to request up-to-date documents from the Users, even though they have verified their identity in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the Barginex’ s Privacy Policy and related regulations/laws.

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

2. Compliance Officer

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

a. Collecting Users’ identification information.

b. Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations.

c. Monitoring transactions and investigating/determining any significant deviations from normal activity.

d. Implementing a "records management system" for appropriate storage and retrieval of documents, files, forms, and logs.

e. Updating risk assessment system regularly.

f. Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, financing of terorism and other illegal activity.

3. Monitoring Transactions

Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Barginex relies on data analysis as a risk-assessment and suspicion detection tool. Barginex performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting. System functionalities include:

1) Daily check of Users against recognized “blacklists” (e.g. OFAC), compiling transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports if applicable.

2) Case and document management.

With regard to the AML/KYC Policy, Barginex will monitor all transactions and it reserves the right to:

-ensure that transactions of suspicious nature are reported to the proper law enforcement authority through the Compliance Officer;

-request the User to provide any additional information and documents in case of any suspicious transaction;

-suspend or terminate User’s Account when the account is on suspicion of engaging in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to determine whether such transactions are to be reported and treated as suspicious or bona fide/legal.

3) Due to AML-KYC procedures, if you want to transfer money worth more than 5 bitcoins, you have to fill out our form in which you accept that your statement is correct. In this form, you have to fill in your name, surname, full address, telephone number, residential address and nationality sections. Having done these, you need to approve/ratify the given information.

4. Risk Assessment

Barginex, in line with the local and international requirements/statutory duties, has adopted a risk-based approach to combat the money laundering, financing of terrorism. By adopting a risk-based approach, Barginex is able to ensure that measures to prevent or mitigate money laundering and financing of terrorism are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.

We chose to work with civic because, during the ID verification process, users have to pass a liveness test and selfie comparison with their ID. Optical character recognition (OCR) ensures that the document’s real owner is being verified.

Besides Civic allows for a simplified user onboarding experience as users only need to submit their data once in the Civic app to get verified.

With Civic Reusable KYC, organizations quickly have proof of identity information being authenticated by a trusted institution, thus, eliminating the sharing of additional data.