Last updated 28 May 2021
Below you will find the Anti-Money Laundering and
Counter-Terrorist Financing Policy (referred to as AML/CTF
Policy) of Bullz Capital which is operating the website
https://Bullz Capital/. Bullz Capital is a privately-owned limited liability company
incorporated under the laws of United Kingdom with registration
number: 11783463 and registered address office at 3rd Floor, 120
Baker Street, London, England, W1U 6TU . Bullz Capital
hereinafter can be referred to as “CB”, “Bullz
Trade”, “We”, “Our”,
“Company”, and “Us” and include its
owners, directors, investors, employees, or other related
parties. The terms “User”, “You” and
“You're” refer to a User of the online platform
https://Bullz Capital/
Our focus is to absolutely maintain the uncompromised and legal
provision of services – that’s why our goal is to
strictly follow the local and international laws and
regulations, outlined in our AML/CFT procedures. Given this
information, Bullz Capital kindly implements this policy in
accordance with the following:
-
DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 30 May 2018 amending Directive (EU) 2015/849 on the
prevention of the use of the financial system for money
laundering or terrorist financing, and amending Directives
2009/138/EC and 2013/36/EU
-
the Estonian Money Laundering and Terrorist Financing Act and
other legal guidelines are given by the Estonian Minister of
Finance and the Estonian Financial Intelligence Unit
-
any other international or local laws and regulations
applicable wherever Bullz Capital may operate its facilities;
For Bullz Capital it is of great importance to correspond its
activities and services with the rules and industry standards
set in the countries where our platform might be operating in.
We comply with all legal requirements and cooperate with the
relevant national regulators. Our focus is to avoid
participating in any kind of illegal or criminal activity, as
well as do anything in our power to prevent such actions.
This anti-money laundering and counter-terrorist financing
policy is part of Bullz Capital’s Terms of Use. Please be
informed that by continuing to use our services and browsing our
website, you agree that you have read and agreed to everything
stated in the Terms of Use and other relevant policies of Bullz
Trade.
Any terms that by any reason are not initially stated in this
document, shall carry the same interpretation as those stated in
the Terms of Use.
Definitions
When referring to “Applicable Laws”, we understand the law in force for the time being within the
territory of any country Bullz Capital might be operating in;
When referring to an “Ultimate Beneficial
Owner”
we mean:
-
The natural person who has direct or indirect ownership of
over 25% (twenty-five percent) of the shares of a legal
entity. ‘Indirect’ means the person in question
has ownership in another legal entity which, on the other
hand, owns partially or fully the legal entity that is about
to be verified, or similar or more complex ownership
structure;
-
The profits of the legal entity are entitled to the natural
person and they exceed 25% (twenty-five percent) of all the
profits;
-
When it comes to the management of the legal entity, the
natural person, who is also a shareholder, has the right to
directly or indirectly appoint or elect this management. They
also have supervision functions.
-
It’s important to be stated that more than 50% of the
voting rights in the legal entity belong to the natural person
in question.
-
When it comes to influencing the legal entity as a result of
an agreement or of the articles that are associated with the
legal entity, the natural person has the right and ability to
do so.
When referring to “document(s)” in the context of
user verification/identification in the Bullz Capital Terms of
Use and policies, we refer to:
-
documents that prove anyone’s identity and are used to
verify the latter such as National ID Cards and Passports and
any other government-issued identification document;
-
any documents that may be used for a registered address of a
natural person or a legal entity to be verified. Those might
be, but not limited to, any bank statements or utility bills,
or
-
any other types of documents as may be notified by Bullz
Capital now and then;
As “Politically Exposed Person” we
refer to any natural person that is himself or is a family
member or close associate to a natural person who operates as:
-
Head of state, head of government, minister, and deputy or
assistant minister;
- Member of Parliament or similar legislative bodies;
- Member of the governing bodies of political parties;
-
Member of supreme courts, of constitutional courts or other
high-level judicial bodies, the decisions of which are not
subject to further appeal, except in exceptional
circumstances;
-
Member of courts of auditors or the boards of central banks;
-
Ambassador charges d'affaires and a high-ranking officer in
the armed forces;
-
Member of the administrative, management, or supervisory
bodies of State-owned enterprises;
-
Director, deputy director, or member of the board or
equivalent function of an international organization.
By using the term “Sanction Lists”
we refer to every natural person, legal entity, or even a
country that is suspected to or are involved in any kind of
illegal or criminal actions. When we talk about such lists, we
have in mind those provided by OFAC, EU, UN, HMT.
By “Suspicious Transactions” we refer to the
following activities. It doesn’t matter whether they are
attempted or executed:
-
What do we mean by terrorist financing: those are transactions
in possession of a person acting in good faith that is about
to be collected fully or partially by any terrorist or
terrorist organization or any other organization that may be
involved in any kind of terrorist activities; or
-
What exactly is a transaction of an Unusually Complexity:
those are transactions to a person acting in a good faith that
is unusually constructed or in a manner of unjustified
complexity; or
-
How do we define malicious purpose: those are transactions
that to a person acting in good faith do not appear true and
sincere or have some kind of a sound economic rationale; or
-
Money Laundering: by money laundering, we figure transactions,
which to a person acting in good faith appear to be hiding
criminal deeds in reality – the main goal of money
laundering is to hide the real origin of that amount of money.
Usually, organizations that generate huge profits via illegal
activities such as drug selling, weapons selling, and human
trafficking use the money laundering processes.
Money Laundering Reporting Officer
In order for our AML/CTF policies to be compliant with the law,
Bullz Capital uses the cooperation of an authorized Money
Laundering Reporting Officer (MLRO). They can provide us with
relevant legislation, regulations, as well as strict rules, and
industry guidelines. We state that the MLRO acts independently
when it comes to proofreading our policies and navigates us
thoroughly through the process of regulations.
The same MLRO is responsible for interacting with the local or
international law enforcement authorities in order to prevent
money laundering, terrorist financing, and other illegal
activities.
Why is User Verification so important?
When it comes to cryptocurrency trading, selling, and buying,
the industry-standard manages to battle money laundering and
terrorist financing activities through the so-called Customer
Due Diligence (CDD). By using the CDD, Bullz Capital expects
every natural person who expresses their interest in trading
fiat money or crypto on Bullz Capital to prove their identity by
various verification methods. The same goes along with the
respective company’s Ultimate Beneficial Owners if a legal
entity wants to trade fiat or crypto on the Bullz Capital
platform.
We strictly follow the Know-Your-Customer rules (KYC). We expect
every user to present the required identity verification
documents when asked to. For verification purposes, we might
rely on licensed and professional third-party services to help
us authenticate the identity documents that the user has
provided.
After passing the procedure of verification, each and every
customer can transact fiat or crypto on the Bullz Capital
platform only when using bank cards or electronic money services
accounts in their own name only.
The procedure of Natural persons identification
Each natural person has the right to execute fiat or crypto
transactions using the Bullz Capital platform. In order to do
so, first, every natural person shall identify themselves. This
is done by simply providing the following data:
- their full name;
- their date of birth;
- their resident address;
-
ID card or international passport or any other kind of
government-issued document that has their photograph, date of
birth, and personal identification number;
-
we might ask you to prove your address of residence by
providing a utility bill or bank statement that cannot be
older than 3 months at the time of the verification procedure;
-
we might also like you to provide a photograph of yours
holding your identification document that also has your
photograph;
There are some instances when a natural person may come from a
high-risk third country. If we consider it appropriate, Bullz
Trade may also ask for:
-
you to provide us with information regarding the source of
your funds and wealth;
-
letting us know of the reasons behind your decision to perform
the desired transaction;
-
we may enhance the monitoring of our business relations by
increasing the applied control. We might also select
transaction patterns that we consider of need for further
examination.
Process of Identification of Legal Entities and Ultimate
Beneficial Owners
General identity information
We state that each legal entity has the right of using the Bullz
Trade services only after passing successfully our verification
process. Whether the entity would like to transact with fiat or
crypto, it is mandatory for it to pass through the verification
process. To start this process, please write to
support@bullzcapital.com
We require:
In order to open a corporate account, please send us the
following data to
support@bullzcapital.com:
- name;
- registered number in any national register;
-
legal form in accordance with the law of the place of
registration;
-
address of the corporate seat and address of management;
- Certificate of Incorporation;
- Articles/Memorandum of Incorporation;
-
Bank Statement not older than 3 months stating the Company
Address;
Some of the additional verification measures
We count on the customer due diligence (CDD) procedure –
thus, with all due respect to business, we further apply the
following safety measures:
-
we require to obtain any additional information of relevance
regarding the user, the beneficial owner, or the politically
exposed person – practically anyone that has access to
the Bullz Capital account;
-
we may also ask for some additional information regarding the
essence of the business relationship;
-
we may ask you to provide some additional information
regarding the source of funds and wealth of the user, the
beneficial owner, or the politically exposed person;
-
we may ask what are the reason behind the decision of
executing the following transaction;
-
we may ask for the approval of a senior manager in order to
establish or continue executing the transaction in
question;
-
we may enhance the control and monitoring of the business
relationship by increasing the controlling activities as well
as selecting certain transaction patterns in need of further
examination.
Persons with access to the corporate account at Bullz
Trade
If you represent a legal entity, then Bullz Capital will want a
signed letter by the directors' board, the CEO, the managing
director, or any other person in control – with this
letter the legal entity shall indicate who exactly has the right
to operate with the Bullz Capital account on behalf of the
company. In this letter we might request the following data:
- each trader's full name;
- the role of the company;
- email of the trader;
- the physical address of each trader;
- nationality of the trader;
-
any personal Bullz Capital accounts the trader may have;
-
and a scanned copy of the trader’s government-issued ID
card or passport.
Ultimate Beneficial Owners
We at Bullz Capital pay close attention to the identity of the
person who has ultimate effective control over the legal entity.
That’s why we require information regarding all beneficial
owners. This required information may include:
- full name;
- nationality(ies) held;
- photo identification document;
- proof of address.
We don’t want to take any chances – since we are
especially diligent we might deploy some extra safety measures
such as the use of third-party screening providers in case of:
-
structure of the organization where there are multiple levels
of ownership;
-
structure of the organization in various jurisdictions; and
-
when there is a lack of supporting documents in need of
proving the ownership of the legal entity;
Of course, there are instances when one legal entity is in
reality owned by another one. In those cases, we inform you
that Bullz Capital will also require the following:
- name of the owning legal entity;
-
the registered number of the owning entity in any national
register;
-
legal form in accordance with the law of the place of
registration of the owning legal entity;
-
address of the corporation and address of management of the
owning legal entity;
-
the details required of UBOs as above, in relation to
corporate “representatives”.
Screening of the sanctions lists:
Bullz Capital is prohibited from executing transactions with
individuals, companies, or countries that are to be found in
sanctions lists. Such lists are provided by the United Nations,
European Union, UK Treasury, US Office of Foreign Assets Control
(OFAC), and other governments and organizations.
Politically Exposed Person screening
One of our goals is to be able to identify politically exposed
persons amongst our users. That’s why we don’t
simply rely only on user-supplied identification declarations,
but also screen by ourselves all individual account holders. We
also inspect any person that has access to a corporate account
against various domestic and international PEP lists.
When do we restrict or deny services?
Bullz Capital keeps the right to downgrade or ban any user for
who we believe has provided inadequate, insufficient, or wrong
personal information, or who is happened to be listed on a
sanctions list. We keep the right to determine whether the
provided information is adequate or sufficient for the needs of
the transactions made. We keep the right to determine the
appropriate verification for each and every customer. Without
prior notice, we may terminate the registration of a user if the
above-mentioned cases are present. We then may express a
requirement for additional identity verification.
If we suspect that an account is registered and operated under a
false name, then Bullz Capital keeps the right to ultimately and
immediately terminate the registration of the account in
question. Bullz Capital does not need to inform the user in
advance of actions of this sort.
It’s important for you to know that Bullz Capital keeps
its right to ask occasionally for users to verify their identity
once again if we have suspected and witnessed some kind of
unusual activity regarding your account or transactions. Even
though you have already passed the verification process at some
point, this does not ultimately mean that you are never going to
be asked to go through the verification procedure once more.
In some cases of nationality, country, or place of residence,
Bullz Capital may implement various restricting verification
levels. These actions may interfere with the user’s
ability to withdraw or deposit their funds on our platform. In
case of losses of any sort, Bullz Capital cannot be held
responsible.
If the Bullz Capital team suspects any kind of suspicious or
illegal activity connected with your account, we keep the right
to terminate it, close it or contact the appropriate enforcement
authorities.
Once the verification process is finished, Bullz Capital removes
itself from potential legal liability in cases when the user
takes part in illegal or criminal activities of any
sort.
Sensitive Personal Information
We collect, share and store any kind of sensitive personal
information with a great focus on strict and outstanding
security measures. They are in accordance with the Bullz Capital
Privacy Policy.
User activity monitoring, analysis, and reporting
By verifying the users’ identity Bullz Capital keeps the
right to monitor and analyze the users’ activity in
accordance with the AML/CTF policies. Trezor Ltds executes a
variety of actions such as capturing data, record-keeping,
investigation management. Some of the system functionalities
include but are not limited to:
1. We keep the right to monitor and carefully examine
transactions made by artificial intelligence such as algorithms,
statistical analyses, classification, and human intervention. We
might do so if we suspect the transactions to be:
- Of an unusual or unnecessarily complex nature;
- Of an unusually large amount;
-
If the transactions are conducted in an unusual pattern;
-
If the transactions lack any economic or lawful purpose;
2. We daily check on users against recognized “black
lists” (e.g. OFAC), as described above;
3. We keep the right to place users on watch and on lists that
decline using our services;
4. If we believe a case should be opened for further
investigation;
5. We might request some additional information if we believe
it’s appropriate and in need for executing our safety
measures;
6. We might be sending internal information if in need;
7. Filling out statutory reports, if applicable;
8. We might case and document management if needed;
We do inform you that we keep track of all the transactions made
on our platform. We keep the right to report any user or their
unusual and suspicious activity to the appropriate law
enforcement agencies through the MLRO. We keep the right to
require any additional information, which we may need in the
future. If we witness strange, unusual, or illegal activity
regarding a user’s account, we keep the right to terminate
and close this account without prior informing the user of our
intentions of doing so. All these measures are strictly followed
by Bullz Capital in order to stop money laundering, terrorist
financing, or any other illegal activity through our
platform.
Risk-based approach
Bullz Capital takes a risk-based approach while trying to follow
the highest industry standards when it comes to preventing money
laundering, terrorist financing, and any other form of illegal
activity. We state that cases of the highest risk shall meet the
highest attention in further examination and closer inspection.
With all that being said, Bullz Capital keeps the right to rank
its users in different risk-based profiles and lists. In order
to do so, we take the following factors in mind:
-
Whether or not the given information is sufficient or
adequate;
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Nature of User’s business/vocational activities; or
-
Guidance notes that were circulated by various governmental
and inter-governmental organizations.
Here is an example of what we consider a case of a top priority:
if you are a natural person from a high-risk third country or
residency; if you are a corporate account holder from a business
with complex ownership that makes it hard for us to acknowledge
the identity of the Ultimate Beneficial Owner, etc.
Bullz Capital keeps this risk categorization private. It is
confidential and Bullz Capital keeps the right to change any
user’s status when it comes to listing them in a specific
high-risk list. Users are not expected to gain information
disclosing this classification by Bullz Capital. On the other
hand, Bullz Capital can reveal information of such sort to the
appropriate enforcement authority if we suspect or witness
suspicious or illegal activity regarding your account or the
transactions made.
Modifications and additional policy updates
This AML/CTF policy may be periodically reviewed, updated,
changed, and revised. The revised draft will be uploaded on
https://Bullz Capital/
and will reflect the modified date of the terms. It’s up
to the user to periodically check on our website if there are
any changes or updates regarding this policy. If a user
continues to use our services, then we assume they have agreed
to the latest version of this policy.
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