AML Policy
1. Introduction
TigraBit (“the Website”) is owned and operated by Jetstream Point Ltd. (“TigraBit,” “we,” or “us”), a company registered at Sea Urchin Street, San Pedro Town, Amergris Caye, Belize, under the Commercial Register of the Belize Companies & Corporate Affairs Registry (registration number 000046950).
This Anti-Money Laundering (“AML”) Policy outlines TigraBit’s approach to preventing Money Laundering (“ML”) and Terrorist Financing (“TF”).
TigraBit recognizes that its services may be targeted by individuals or groups seeking to launder funds or facilitate terrorism financing. The Company is committed to fostering a robust compliance culture to mitigate these risks.
2. Policy Statement and Objectives
TigraBit strictly prohibits the use of its platform for any form of illicit activity, including ML, TF, and sanctions violations. To this end, TigraBit is committed to implementing global best practices, including:
Establishing written policies, procedures, and controls to prevent ML, TF, and sanctions violations.
Appointing a compliance officer to oversee AML implementation.
Providing regular education and training to relevant personnel.
Conducting independent reviews and continuous monitoring of AML systems and controls.
This AML Policy outlines the procedures, systems, and controls implemented by TigraBit to prevent and detect ML and TF activities.
3. Chief Compliance Officer
TigraBit has appointed a Chief Compliance Officer (“CCO”) to coordinate the implementation of this AML Policy. The CCO is responsible for:
Developing and maintaining AML initiatives.
Revising the AML policy to address new regulatory requirements.
Investigating and reporting suspicious or unusual activity to the Financial Intelligence Unit (“FIU”) of Curaçao.
The CCO reports directly to the Board and has the authority to submit Suspicious Transaction Reports (“STRs”) independently.
4. Responsibility of Employees, Directors, and Officers
All employees, directors, and officers of TigraBit must comply with this AML Policy. They are required to:
Be vigilant in identifying and preventing ML and TF activities.
Report any suspicious transactions or activities to the CCO without delay.
Failure to comply with these requirements may result in disciplinary action. TigraBit will provide regular AML training to employees to ensure they can effectively identify and report suspicious activities.
5. Know-Your-Customer (KYC) Measures and Transaction Monitoring
TigraBit has implemented risk-based controls, policies, and procedures to mitigate ML and TF risks. The Company applies robust KYC and ongoing monitoring measures as outlined below.
5.1. KYC Measures
Customer Due Diligence (“CDD”): TigraBit uses CDD processes to develop customer risk profiles. These processes involve collecting and verifying customer information during onboarding and monitoring account activities.
Customer Information Collection: TigraBit collects details such as name, address, date of birth, wallet address, and country. This information must be provided before issuing a funding address (e.g., QR code).
Geoblocking Prohibited and Sanctioned Jurisdictions: Customers must declare they are not located in restricted jurisdictions. TigraBit implements IP-based geo-blocking for prohibited and sanctioned regions.
Sanctions Screening: Wallet addresses are screened against sanctions databases using third-party tools like Chainalysis.
5.2. Ongoing Monitoring
TigraBit performs continuous monitoring to identify ML, TF, or other illicit activities. Measures include:
Transaction Monitoring: Manual and automated processes flag red-flag behaviors. Suspicious activities may result in additional scrutiny or account suspension.
Sanctions Re-Screening: Customer wallet addresses are periodically re-screened against sanctions lists.
Unusual Activity Identification: Regular reports analyze transaction patterns for anomalies, high-risk behaviors, or unusual activities.
Anti-Mixing Measures: The use of mixers, tumblers, or anonymity-enhancing tools is prohibited.
Chainalysis Reviews: All deposits and withdrawals are assessed for risks using Chainalysis, with potential account suspensions for flagged activities.
Withdrawal Threshold KYC: Enhanced due diligence is conducted for withdrawals exceeding risk-based thresholds.
Ban Evasion Detection: TigraBit uses third-party tools to detect multi-account use or evasion attempts.
5.3. Enhanced Due Diligence (EDD)
When red flags are triggered, TigraBit performs EDD, which may include:
Verifying the customer’s full legal name, citizenship, and address.
Requiring government-issued identification and proof of wealth or source of funds.
Engaging third-party providers for verification where necessary.
5.4. Blocking of Customers
TigraBit reserves the right to block or suspend customers who:
Fail to provide required identification.
Provide fake or misleading information.
Are located in restricted jurisdictions.
Are listed on global sanctions or watch lists.
Engage in suspicious or prohibited activities.
6. Reporting
If a customer is identified as being linked to ML, TF, or other illicit activities, TigraBit will file an appropriate report with the FIU. All reports are handled confidentially and in compliance with legal obligations.