HILT VENTURES BANK SECRECY ACT (BSA)/ANTI-MONEY LAUNDERING (AML) POLICY
It is the policy of Hilt Ventures, LLC (hereinafter “Hilt Ventures”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.
Money laundering is generally defined as “engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.” Generally, money laundering occurs in three stages. Illicit proceeds first enter the financial system at the "placement" stage, where funds generated from criminal activities are converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other assets, accounts, or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership, and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.
BSA/AML POLICIES & CONTROLS
Hilt Ventures’ BSA/AML policies and internal controls are designed to ensure compliance with all applicable BSA and AML regulations and will be reviewed, updated, and independently audited on a regular basis to account for both changes in regulations and changes in Hilt Ventures’ business model. BSA/AML policies set forth the minimum standards of compliance and establishes a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the institution. Hilt Ventures prohibits transactions with individuals, entities, and countries that are on prescribed sanctions lists and therefore screen against UN, EU, UK Treasury, US Office of Foreign Assets Control (OFAC), and other sanctions lists in all jurisdictions in which it operates.
The purpose of the BSA/AML Program is to establish a procedure for Hilt Ventures to operate in compliance with FinCEN regulations regarding anti-money laundering, suspicious activity, and other reporting responsibilities. On March 18, 2013, FinCEN released guidance requiring persons administrating or exchanging virtual currencies to register as a money services business (MSB), specifically a money transmitter, and thus comply with FinCEN MSB regulatory requirements to establish an AML program, complete certain government filings, and retain records for presentation as required.
APPLICABILITY & SCOPE
FinCEN’s BSA/AML regulatory requirements are applicable to Hilt Ventures under FinCEN Guidance FIN-2013-G001. Hilt Ventures operates a multistate network of automated cryptocurrency kiosks (“kiosks”) which enable customers to perform three exchange services: 1) U.S. dollar-denominated cash (or “fiat money”) for cryptocurrency; 2) cryptocurrency for cash; and, 3) cryptocurrency for cryptocurrency (or “crypto-to-crypto”). As such, and in response to the threat of potential money laundering activities conducted via its exchange services, Hilt Ventures has adopted an anti-money laundering policy, as summarized above, which is followed by all of its employees, officers, agents, owners, and directors.
WHAT THIS MEANS FOR YOU
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This means that Hilt Ventures, when you seek to conduct a transaction at one of the Kiosks, will ask you to provide information so that we may reasonably identify you in compliance with the USA PATRIOT Act. We may also ask you to provide your driver’s license or other identifying documents. We will retain copies of all identifying information you provide.
FinCEN Guidance FIN-2013-G001 “Application of FinCEN's Regulations to Persons Administering, Exchanging, or Using Virtual Currencies.”