Last updated: 1 January 2025
1. Overview
Bitlaya, operated by Kaldex System OÜ, is committed to preventing money laundering, terrorist financing and other financial crimes. Our AML programme is designed to comply with applicable laws and the requirements of our principal licensed entity, POLARIS MONEY SERVICES INC. (FINTRAC Registration No. C10001253), which holds a Money Services Business licence valid 17 October 2025 – 30 June 2028.
2. Regulatory Compliance
We operate under the oversight of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related regulations.
3. Risk-Based Approach
We assess the risk of money laundering and terrorist financing based on factors including customer type, geographic location, transaction size and nature of the business relationship. Higher-risk relationships are subject to enhanced scrutiny.
4. Customer Due Diligence (CDD)
All customers must complete identity verification before transacting. Required information includes:
- Full legal name and date of birth
- Government-issued photo identification
- Proof of residential address
- Source of funds declaration for higher-value transactions
5. Enhanced Due Diligence (EDD)
EDD is applied to politically exposed persons (PEPs), customers from high-risk jurisdictions, and transactions above defined thresholds. EDD may include senior management approval and additional source-of-wealth verification.
6. Prohibited Activities
- Transactions involving sanctioned individuals, entities, or countries (OFAC, UN, EU lists)
- Structuring transactions to avoid reporting thresholds
- Use of the platform for proceeds of criminal activity
- Providing false identity or beneficial owner information
7. Prohibited and High-Risk Jurisdictions
We do not provide services to residents of FATF-blacklisted jurisdictions or countries under comprehensive sanctions. The list is reviewed quarterly and updated as required.
8. Monitoring and Reporting
Transactions are monitored in real time using automated screening tools. Suspicious transactions are escalated to our MLRO and, where required, reported to FINTRAC via Suspicious Transaction Reports (STRs) or Large Cash Transaction Reports (LCTRs).
9. Record Keeping
All transaction records, customer identification documents and due diligence records are retained for a minimum of five (5) years from the date of the last transaction.
10. Training and Awareness
All staff with customer-facing or compliance roles receive AML training on an annual basis covering indicators of suspicious activity, reporting obligations and internal escalation procedures.
11. Contact
AML compliance queries: compliance@bitlaya.com