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 XBits OÜ which is operating the website https://x1.gr/
. XBits OÜ is a privately-owned limited liability company incorporated under the laws of Estonia with registration number: 14647515 and registered address office 408, 5 Mustamäe street, Kristiine district, Harju county, Tallinn, 10616, Estonia. xBits OÜ, hereinafter can be referred to as “xBits”, “X1”, “We”, “Our”, “Company”, and “Us” and include its owners, directors, investors, employees, or other related parties. The terms “User”, “You” and “Your” refer to a User of the online platform https://x1.gr/
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, X1 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 X1 may operate its facilities;
For X1 it is of great importance to corresponding 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 doing anything in our power to prevent such actions.
When referring to “Applicable Laws”, we understand the law in force for the time being within the territory of any country X1 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 belonging 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.
- 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 X1 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, X1 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, X1 expects every natural person who expresses their interest in trading fiat money or crypto on X1 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 X1 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 X1 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 X1 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, X1 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 X1 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 [email protected]
In order to open a corporate account, please send us the following data to [email protected]:
- 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 X1 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 X1
If you represent a legal entity, then X1 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 X1 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 X1 accounts the trader may have;
- and a scanned copy of the trader’s government-issued ID card or passport.
Ultimate Beneficial Owners
We at X1 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 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 X1 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:
X1 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 organisations.
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?
X1 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 X1 keeps the right to ultimately and immediately terminate the registration of the account in question. X1 does not need to inform the user in advance of actions of this sort.
It’s important for you to know that X1 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, X1 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, X1 cannot be held responsible.
If the X1 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, X1 removes itself from potential legal liability in cases when the user takes part in illegal or criminal activities of any sort.
Sensitive Personal Information
User activity monitoring, analysis, and reporting
By verifying the users’ identity X1 keeps the right to monitor and analyse the users’ activity in accordance with the AML/CTF policies. X1s 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 both 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 X1 in order to stop money laundering, terrorist financing or any other illegal activity through our platform.
X1 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, X1 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;
- 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.
X1 keeps this risk categorization private. It is confidential and X1 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 X1. On the other hand, X1 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://x1.gr/
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.
If you have any questions concerning the above, feel free to contact us at [email protected]