LAST UPDATED: March 1, 2019
1. PURPOSE OF OUR PROGRAM
BitLeague LLC and affiliates (hereinafter “we”) have established and implemented an Anti-Money Laundering,
Anti-Terrorist Financing, and Trade & Economic Sanctions Program (“AML/ATF/Sanctions Program” or “Program”)
to ensure a robust and compliant digital asset trading platform. We want to promote legal, transparent
business activities and maintain a strong reputation among our customers, regulators, and the digital asset
2. OUR ROLE AND ACTIVITIES
We are a global digital asset trading platform or marketplace, where traders come as buyers and sellers
(commonly referred as market-makers and market-takers). For clarity, buyers and sellers trade with each
other and not with BitLeague LLC and affiliates. We are not a counterparty to any trade. Our Services are
available through BitLeague LLC and affiliates, associated application program interfaces and/or mobile
applications. In addition, Users may purchase term deposit products and collateral lending products on our
3. REGULATORY LANDSCAPE
We understand that regulatory bodies have taken a diverse approach to the laws and regulations regarding
digital assets. As a trading platform, we believe that Bitcoin is a digital asset that is emerging as an
innovative alternative asset class; and therefore, digital assets should not be called currency or money.
Disclosure: Digital assets are not fiat money nor fiat currency. Digital assets such as Bitcoin are NOT
backed by any government or central bank. Nevertheless, since we provide a valuable feature to our customers
who wish to trade and settle in fiat, we believe it is imperative to maintain a robust AML/ATF/Sanctions
program as we connect with the fiat financial system. We may at times have opinions of the different
regulatory approaches taken by various government bodies; however, at all times, we will fully abide by
rules and regulations of the respective countries we operate in; mainly, the United States. We regularly
reach out to regulators and industry on the best approach to regulating digital asset businesses.
Furthermore, BitLeague LLC and affiliates do not accept certain customers. To maintain our strong reputation
in the market and ensure a robust compliant marketplace, we have decided to not seek nor accept customers
from certain jurisdictions including any jurisdiction which has US Sanctions imposed on it. Please refer the
“Restricted Territories” in Terms and Conditions for certain jurisdictions we do not offer service.
We cooperate with governments and respect regulations and comply with applicable regulations. As good
corporate citizens, we may be asked for information from law enforcement authorities and will assist if
permissible by law as law enforcement conduct investigations to pursue and thwart illicit activity. What
this also means is that our platform is intended for law abiding customers. We welcome the opportunity to
earn your business, and in return we require that you act legally and properly on our platform.
4. OUR AML/ATF PROGRAM
We have designed our Program to reasonably prevent money laundering and terrorist financing through a
risk-based, multi-layer control system.
The first layer includes a stringent customer identification program, including verifying the identity of
our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain
for non-natural persons their entities’ beneficial owners/natural persons consistent to international
standards such as the Financial Action Task Force (FATF).
The second layer includes a risk-based system to warrant additional customer due diligence. To accomplish
this, we screen our customers (including beneficial owners) against the entities/persons on the United
States Office of Foreign Assets Control (OFAC) Sanctions Lists, and the United Nation Security Council
Sanctions List, among other government-provided lists of sanctioned individuals and entities. We also may
screen against other lists on a discretionary basis to protect our reputation and customers.
The third layer includes ongoing monitoring for suspicious activity. If our Program suspects or has reason
to suspect suspicious activities have occurred, we will file suspicious activities reports with local
regulators. A suspicious transaction is often inconsistent with a customer’s known and legitimate business,
or personal activities.
These are the primary components of our compliance program; however, the most important glue or connection
to these layers are our leadership team and staff, including AML/Risk personnel that execute training,
oversight and a sound compliance culture.
Trading in digital assets is considered high risk. Digital assets such as Bitcoin are NOT backed by any
government or central bank. The risk of loss in trading or holding digital assets can be substantial. You
should carefully consider whether interacting, holding, or trading digital assets is suitable for you in
light of your financial condition.
If you have questions or require assistance with our customer due diligence controls, please reach out to
our 24/7 customer service representatives by email at firstname.lastname@example.org.