Our KYC and AML Policy

1. Introduction and Purpose

Bitsika ("the Company," "we," "us," "our") is committed to providing access to digital content including Virtual Cards, Gift Cards, and Game Top-Ups for users, primarily in the developing world. We are dedicated to operating with the highest ethical standards and in compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations.

This KYC/AML Policy outlines the procedures we follow to prevent our services from being used for money laundering, terrorist financing, fraud, or any other financial crime. As a platform that facilitates the use of cryptocurrency for purchasing digital goods, we recognize our responsibility to implement robust, risk-based compliance measures.

2. Scope and Application

This policy applies to all users of the Bitsika platform, all employees, contractors, and anyone acting on behalf of Bitsika. It governs our relationship with users from the point of onboarding and throughout the lifetime of their interaction with our services.

3. Key Definitions

a. KYC (Know Your Customer): The process of identifying and verifying the identity of our users.

b. AML (Anti-Money Laundering): The set of procedures, laws, and regulations designed to stop the practice of generating income through illegal actions.

c. CTF (Counter-Terrorist Financing): Measures designed to stop the flow of funds to terrorist organizations.

d. Sanctions Lists: Official lists of individuals, entities, and countries subject to economic sanctions (e.g., OFAC, UN, EU).

e. CDD (Customer Due Diligence): The process of gathering and assessing information about a customer to determine their risk profile.

f. EDD (Enhanced Due Diligence): A higher level of scrutiny applied to higher-risk customers.

4. Customer Identification Program (KYC)

In line with our commitment to security and legality, Bitsika requires all users to complete a full KYC verification before they can initiate any transaction on our platform. There are no transacting accounts without verification.

The KYC process is as follows:

a. User Registration: To start, a user must provide a valid phone number to create an account.

b. Identity Verification: Before any transaction is permitted, the user must provide:

i. Government-Issued Photo ID: A clear, legible image of a valid passport, national ID card, or driver's license.

ii. Live Photo / Liveness Check: A real-time photo of the user holding their government-issued ID next to their face. This prevents the use of fraudulent or stolen documents.

c. Verification Partner: To ensure accuracy, privacy, and security, all identity verification will be performed through a certified, specialized third-party provider (e.g., Sumsub, Onfido, Jumio). This ensures that our data handling meets the highest standards.

d. Data Accuracy: Users are responsible for entering accurate information. Providing incorrect or fraudulent data will result in the immediate blocking of the account and a permanent ban from using Bitsika's services.

5. Geographic Restrictions and Sanctions Screening

Bitsika is committed to complying with international sanctions and will not facilitate transactions that violate these laws.

a. Prohibited Jurisdictions: Our app is not available for download or use in any country subject to comprehensive sanctions or embargoes, including but not limited to those on the OFAC (US) and EU sanctions lists.

b. IP and Geolocation Blocking: We employ technical measures to block access to our platform from prohibited jurisdictions.

c. Ongoing Screening: All user data will be screened against global sanctions lists (including OFAC, UN, and EU) at the time of registration and on an ongoing basis. If a match is found, the account will be immediately frozen, and a report will be filed with the appropriate authorities.

6. Transactional Limits and Monitoring

Given our focus on digital content for users in developing regions, we have implemented a risk-based approach to transaction limits.

a. Per-Transaction Limit: No user may transact more than $5,000 (USD equivalent) in a single transaction. This applies to the purchase of Virtual Cards, Gift Cards, and Game Top-Ups.

b. Cumulative Limits: While we require full KYC upfront, we may implement additional cumulative monitoring thresholds. For example, if a user approaches a high cumulative volume (e.g., $10,000 or more), we may trigger a review or Enhanced Due Diligence (EDD) to better understand the user's source of funds and intended use of the digital content.

c. Cryptocurrency-Only Policy: Bitsika does not accept deposits of any fiat currency. Users can only deposit and transact using mainstream cryptocurrencies like USDT and Bitcoin (BTC). This policy clarifies that we are not a money transmitter or a fiat exchange.

7. Anti-Money Laundering (AML) Procedures

Our AML framework is designed to detect and prevent the misuse of our platform.

a. Customer Due Diligence (CDD): We conduct CDD on all customers. By verifying their identity, we form a reasonable belief that we know the true identity of the user. This helps ensure that our platform is not used to launder illicit funds.

b. Risk Assessment: We use a risk-based approach to assess all users. Factors that may increase a user's risk profile include:

i. Geographic Risk: Transactions originating from or flowing to high-risk jurisdictions.

ii. Behavioral Risk: Unusual transaction patterns, such as rapid spending immediately after a deposit (a "pass-through" pattern).

iii. Asset Risk: Transactions involving privacy coins or assets associated with high-risk decentralized finance (DeFi) protocols.

c. Ongoing Monitoring: All user accounts and transactions are subject to continuous monitoring. This allows us to detect suspicious activity that may not be apparent from a single transaction. If we detect behavior inconsistent with a user's profile or normal activity, it will be flagged for review.

d. Combating Terrorist Financing (CTF): As part of our sanctions screening and monitoring procedures, we actively work to prevent terrorists or terrorist organizations from using our platform. Any suspicious activity related to potential terrorist financing will be immediately reported.

8. Reporting and Enforcement

We take our legal obligations to report suspicious activity very seriously.

a. Suspicious Activity Reports (SARs): If Bitsika suspects or has reason to know that any transaction or funds are derived from illegal activity, or are intended for illegal purposes (including terrorist financing), we will file a report with the relevant financial intelligence unit or law enforcement agency.

b. Account Bans for Illicit Activity: Users suspected of engaging in illicit or law-breaking activities with the content they purchase from us will have their accounts permanently banned.

c. Cooperation with Authorities: We will fully cooperate with law enforcement and regulatory authorities in their investigations, providing all necessary information as permitted and required by law.

9. Data Privacy and Record Keeping

We are committed to protecting the privacy of our users.

a. Encryption: All user data, including KYC documents and transaction history, is stored in encrypted form.

b. Non-Disclosure to Third Parties: We do not sell, rent, or trade your personal information. Data is not passed on to third parties for their marketing purposes. The only exceptions are:

i. Our verified KYC/AML partners for the sole purpose of identity verification.

ii. Law enforcement or regulatory agencies as required by law.

c. Record Retention: We will retain all customer records, transaction data, and KYC documentation for a minimum of five (5) years, or as otherwise required by applicable law, to enable effective investigations by authorities if necessary.

10. Policy Review

This policy will be reviewed annually, or more frequently if there are material changes to our business model, the regulatory landscape, or if a compliance incident occurs.

11. Countries where our services are unavailable.

United States of America, Cuba, Iran, North Korea (Democratic People's Republic of Korea), Syria, Crimea Region of Ukraine, Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) regions of Ukraine, Russia, Belarus, Venezuela, Afghanistan, Central African Republic, Democratic Republic of the Congo, Iraq, Lebanon, Libya, Mali, Myanmar (Burma), Nicaragua, Somalia, South Sudan, Sudan, Yemen, Zimbabwe, Eritrea, Ethiopia, Guinea, Guinea-Bissau.