AML

 

Anti-Money Laundering (AML) Policy

Introduction

BitBrave – Limited Partnership Investment Fund (“the Fund”) is committed to complying with Estonian and European Union (EU) anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, including the Estonian Money Laundering and Terrorist Financing Prevention Act and the guidelines of the Financial Action Task Force (FATF). Given the Fund’s investment activities in cryptocurrencies, we recognize the unique AML risks associated with digital assets and have implemented enhanced measures to mitigate these risks.

1.         Scope

This AML policy applies to all activities of the Fund, its management, employees, and service providers. The policy outlines procedures to detect, prevent, and report money laundering and terrorist financing activities in compliance with applicable laws and regulations.

2.         Know Your Customer (KYC) and Customer Due Diligence (CDD)

2.1  KYC Requirements

    • The Fund conducts thorough KYC checks for all investors before allowing participation, including identification and verification of identity using government-issued identification and proof of address.
    • For legal entities, the Fund verifies the ultimate beneficial owners (UBOs), corporate structure, and registration documents.

2.2  Enhanced Due Diligence (EDD)

    • EDD is applied for high-risk investors, politically exposed persons (PEPs), or investments originating from high-risk jurisdictions identified by FATF.
    • EDD includes additional documentation, source of funds verification, and ongoing monitoring.

2.3  Cryptocurrency-Specific Measures

    • Investors contributing funds in cryptocurrency must provide proof of ownership of the digital wallet used for the transaction.
    • Transactions involving cryptocurrencies are subject to blockchain analysis to assess the origin of funds and detect links to illicit activities.

3.         Reporting Obligations

3.1  Suspicious Activity Reporting (SAR)

    • The Fund complies with its legal obligation to file Suspicious Activity Reports (SARs) with the Estonian Financial Intelligence Unit (FIU) if money laundering, terrorist financing, or other illicit activities are suspected.

3.2  Record Keeping

    • The Fund retains all KYC, CDD, transaction records, and related documentation for a minimum of five years as required by Estonian law.
    • All records are securely stored to protect confidentiality.

4.         Risk Assessment

4.1   The Fund conducts an annual AML risk assessment to evaluate and address vulnerabilities in its operations, especially regarding cryptocurrency investments.

4.2   Risk assessments focus on:

    • Geographic risks (e.g., transactions involving high-risk countries).
    • Product and service risks (e.g., cryptocurrencies with high anonymity features).
    • Investor-specific risks (e.g., PEPs or complex ownership structures).

5.         Staff Training and Awareness

5.1  The Fund ensures all employees and service providers receive regular training on AML policies, cryptocurrency-related risks, and their legal obligations.

5.2  Training includes:

    • Identification of red flags for suspicious activity.
    • Use of blockchain analysis tools.
    • Legal consequences of non-compliance with AML laws.

6.         Prohibited Activities

The Fund prohibits:

6.1  Investments by individuals or entities listed on sanctions lists maintained by the EU, United Nations, or other relevant authorities.

6.2  Transactions involving cryptocurrencies known for high anonymity (e.g., privacy coins) unless sufficient transparency is established.

6.3  Cash payments or anonymous transactions in any form.

7.         Review and Updates

This AML policy is reviewed and updated annually or as required by changes in applicable laws, regulations, or operational risks. The latest version is available on the Fund’s website.