1. Introduction

BitStake is committed to preventing money laundering and ensuring compliance with applicable AML laws and regulations. This document outlines our AML policies, procedures, and controls to safeguard our platform and users.

2. Company Information

Name: BitStake

URL: https://bitstakeplatform.com/

Description: BitStake exists to bridge the gap between real estate investors and developers, providing a seamless, secure, and efficient solution for both parties. Our platform addresses the challenges faced by both investors and developers by offering a revolutionary alternative to traditional real estate investment. We operate from Level 2/627 Chapel St, South Yarra VIC 3141, Australia. For inquiries, please contact us at info@bitstakeplatform.com.

3. Legal and Regulatory Requirements

BitStake operates in Australia and complies with the following AML laws and regulations:

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)

4. AML Compliance Officer

• Name: Emmanuel Chaplain
• Title: AML compliance officer/ Secretary
• Contact Information: info@bitstakeplatform.com

5. Customer Due Diligence (CDD)

BitStake performs the following Customer Due Diligence (CDD) procedures:

Information Collected

For both developers and investors, we collect:

• Name
• Email
• Phone
• Passport
• ID card/driving license
• VAT/ABN

Verification Process

• We enter the collected information into SumSub.
• Verification results are typically received within 24 to 48 hours.
• We ensure that each user's information is securely stored and not misused.

6. Transaction Monitoring

BitStake monitors transactions to detect and report suspicious activities. This includes:

• Using Stripe for transaction processing and bank transfer for user withdrawals.
• Employing a control panel to monitor each transaction and website analytics.
• Implementing automated systems and manual reviews to identify suspicious patterns such as large transactions, rapid movement of funds, and unusual transaction behaviors.

7. Record Keeping

BitStake maintains records of all customer information and transactions for a minimum of five years. Records include:

• KYC data
• Transaction records

8. Reporting

Suspicious activities are reported to the relevant authorities promptly. Procedures include:

• Identifying and documenting suspicious activities.
• Reporting to the Australian Transaction Reports and Analysis Centre (AUSTRAC).

9. Internal Controls and Training

BitStake has established internal controls to ensure AML compliance, including:

• Regular employee training programs on AML requirements and procedures.
• Written policies and procedures accessible to all employees.
• Implementation of two-factor authentication (2FA) for additional security on user accounts.

10. Independent Audit

BitStake conducts independent audits of its AML program annually. The audits include:

• Reviewing compliance with AML policies and procedures.
• Assessing the effectiveness of transaction monitoring systems.

11. Risk Assessment

BitStake conducts regular risk assessments to identify and mitigate money laundering risks. Factors considered include:

• Customer profile
• Transaction types and patterns
• Geographic risk

12. Sanctions and PEP Screening

BitStake screens customers against sanctions lists and Politically Exposed Persons (PEP) lists. Procedures include:

• Screening during the onboarding process using Jumio and Onfido.
• Ongoing monitoring to identify matches.
• Taking appropriate actions if a match is found.

13. Conclusion

BitStake is committed to maintaining the highest standards of AML compliance. All employees are required to adhere to this policy and report any suspicious activities to the AML Compliance Officer. By following these guidelines, we aim to create a secure and trustworthy platform for our users.