REFINED PROCESSESES

Ensure a more efficient customer experience - customer satisfaction and security are our priority

SERVICE

Our customers services will work with you to enable a smooth passage through our client onboarding and KYC requirements.

TOTAL COMPLIANCE

TheBitWire's team assists with onboarding and manages ongoing due diligence – to ensure clients are protected and their stored personal information is both secure and relevant for purpose.

DOCUMENT & DATA MANAGEMENT

TheBitWire's services and systems are fully compliant with current data protection laws.

CLIENT ACCESS

Clients have access to review transaction history or communicate directly with TheBitWire agents and request bespoke reporting.

KNOWLEDGE & EXPERIENCE

Experienced agents with local knowledge in existing and emerging markets allow our clients to increase their customer base without increasing their risk.

SIMPLE INTEGRATION

Simple integration processes to ensure clients are live within a matter of days in most cases.

CAPACITY

Capacity for large projects, batch transactions and strategic business expansion.

CONSOLIDATED SANCTIONS LISTS

  • UN Consolidated
  • UN Security Council List of Designated Vessels
  • OFAC Consolidated List United States
  • European Union Sanctions List
  • European Council List of Designated Vessels
  • European Council Restrictive Measures on Russian Entities
  • HM Treasury List United Kingdom
  • OSFI Entity List Canada
  • OSFI Person List Canada
  • Canada's Freezing Assets of Corrupt Foreign Officials
  • Public Safety Canada Listed Entities
  • Special Economic Measures Act - Sanctions Canada
  • Canadian Sanctions Justice for Victims of Corrupt Foreign Officials Act
  • DFAT Australia List
  • Liste Unique de Gels France
  • Federal Public Service National Financial Sanctions Belgium
  • Liste des Sanctions Financières Internationales Luxembourg
  • SECO List Switzerland
  • Federal Council Freezing of Foreign Illicit Assets Switzerland
  • MAS List Singapore
  • Singapore First Schedule of the Terrorism (Suppression of Financing) Act
  • Ministry of Home Affairs Banned Organisations India
  • Israel Ministry of Defence
  • Russian ROSFIN Monitoring List
  • Ukraine State Financial Monitoring Blacklist
  • Norway Lovdata Judicial Laws
  • Monaco Ministerial Orders
  • Netherlands Domestic Terrorist List
  • US State Department Nonproliferation Sanctions
  • US Department of State Terror Exclusion List
  • US Department of State Cuba Restricted Entities List
  • Japan Ministry of Finance Sanctions
  • Japan METI - Weapons of Mass Destruction Proliferators
  • Philippines AMLC Sanctions Resolutions
  • New Zealand Police Designated Terrorists
  • Australian National Security Terrorism Lis
  • Thailand Designated Persons List
  • Kenyan Gazette - Sanctioned Entities

Categorisation of Politically Exposed Persons (PEPs)

A politically exposed person (PEP) is an individual who is or has been entrusted with a prominent function.

Bitwire use the Financial Action Task Force (FATF) definition of PEP and PEP Categorisation. FATFis an inter-governmental body established in 1989 by the Ministers of its Member jurisdictions. The FATF currently comprises 34 member jurisdictions and 2 regional organisations, representing most major financial centres in all parts of the globe. The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system.

Due to the risks associated with PEPs, the FATF Recommendations require the application of additional AML/CFT measures to business relationships with PEPs. These requirements are preventive (not criminal) in nature, and should not be interpreted as meaning that all PEPs are involved in criminal activity.

Bitwire PEP Definition and ranking is based on theFATF version: High Risk – Level 1 PEPs

Heads of state and government

Members of government (national and regional)

Members of Parliaments (national and regional)

Heads of military, judiciary, law enforcement and board of central banks

Top ranking officials of political parties

Medium Risk – Level 3 PEPs

Senior management and board of directors of state owned businesses and organisations

Medium-High Risk – Level 2 PEPs

Senior officials of the military, judiciary, and law enforcement agencies

Senior officials of other state agencies and bodies and high ranking civil servants

Senior members of religious groups Ambassadors, consuls, high commissioners

Low Risk – Level 4 PEPs

Mayors and members of local county, city and district assemblies

Senior officials and functionaries of international or supranational organisations

  • current or former senior official in the executive, legislative, administrative, military, or judicial branch of a foreign government (elected or not)
  • a senior official of a major foreign political party
  • an immediate family member of such individual; meaning spouse, parents, siblings, children, and spouse's parents or siblings
  • any individual publicly known (or actually known by the relevant financial institution) to be a close personal or professional associate.
  • a senior executive of a foreign government owned commercial enterprise, being acorporation, business or other entity formed by or for the benefit of any such individual In addition, family members and close associates of PEPs are considered PEPs, and can be risk-ranked as described below: Family members
  • A spouse; a partner (including a person who is considered by his national law as equivalent to a spouse); children and their spouses or partners; and parents (ranked at the same level as the PEP associated with but not higher unless the family member in question is a PEP on his/her own right in which case, the position thus held will determine the risk ranking of thatindividual)

Siblings and in some jurisdictions may also include grandparents, grand children, other bloodrelatives and relatives by marriage (ranked at one level down from the level the PEP associated with is ranked unless the family member in question is a PEP on his/her own rightin which case, the position thus held will determine the risk ranking of that individual)

Close business associates

Any natural person who is known to have joint (or sole) beneficial ownership of legal entitiesor legal arrangements which is known to have been set up for the benefit of a person who is a PEP, or any other close business relations with a person who is a PEP.

Close business colleagues and personal advisors/consultants to the politically exposed person as well as persons who obviously benefit significantly from being close to such a person (ranked at the same level as the PEP associated with but not higher unless the business associate in question is a PEP on his/her own right in which case, the position thus held will determine the risk ranking of the business associate)

Business associates who are not PEPs on their own right but who share a common platform at a board level in non-SOEs whether privately held or not (ranked at one level down from the level the PEP associated with is ranked)

PEPs in State-Owned Enterprises (SOE) High Risk – Level 1 SoEs

Businesses which are 51%-100% state owned

Medium Risk – Level 3 SoEs

Subsidiaries of high risk and medium to high risk businesses as long as these subsidiaries also fit the criteria defined therein relating to the ownership structure and representation on the board

Companies in which % of government control is not defined but there is evidence of state ownership and the government is involved in the company through its representation on the board

Medium to High Risk – Level 2 SoEs

</=50% state owned and where government is represented on the company’s board

Low Risk – Level 4 SoEs

State owned/controlled companies at local or municipal government level regardless of % of ownership as long as government is represented on the company’s board