Legal

Anti-money laundering policy

How we keep BineBit safe from money laundering, terrorist financing and fraud, and what that means for you.

Last updated: [Date of first publication]

Draft for legal review. This document is a working draft and is not yet in force. Items in [square brackets] are placeholders to be completed by BineBit and its lawyers.

Our commitment

BineBit lets people sell crypto and gift cards for cash, hold crypto in a custodial wallet and buy travel eSIMs. Because we move money, we have a legal and moral duty to stop our service being used to launder money, finance terrorism, evade sanctions or commit fraud.

This page summarises our anti-money laundering (AML) and counter-terrorist financing (CTF) programme. It is a public summary, not the full internal policy, and it forms part of our Terms of Service.

Laws we follow

Our programme is built to meet the rules that apply where we operate, including:

  • Nigeria: the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and the rules and guidance of the Securities and Exchange Commission (SEC) Nigeria for digital asset businesses.
  • United Kingdom: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and UK financial sanctions law.
  • International standards set by the Financial Action Task Force (FATF), including its guidance for virtual asset service providers.

Verifying your identity

We must know who our customers are. We verify identity before or soon after you start using BineBit, depending on your region:

RegionWhat we ask for
NigeriaYour BVN and NIN and a selfie, before your first sale. Higher limits may need extra checks.
United KingdomA government-issued photo ID and a selfie before your first sale. We may also ask for proof of address.

We use trusted identity verification partners to check documents and confirm that the selfie matches the ID. You must use your own identity and your own bank account. Accounts and payouts in someone else's name are not allowed.

Extra checks for higher risk

Some situations need more information. We may carry out enhanced due diligence when, for example:

  • you are, or are closely linked to, a politically exposed person (PEP);
  • activity on your account is large, frequent or unusual compared with what we expect;
  • your account or transactions are linked to a high-risk country.

We may ask where your crypto, gift cards or money came from (source of funds) and supporting documents. Until we receive what we need, we may limit your account or pause a transaction.

Sanctions screening

We screen customers, and the crypto addresses that send funds to BineBit wallets, against sanctions lists including those of the United Nations, the UK (HM Treasury, Office of Financial Sanctions Implementation), the European Union and the United States (OFAC), as well as Nigerian lists. We cannot serve people or entities that are sanctioned, or people in countries we do not support.

Monitoring deposits and transactions

Every crypto deposit to a BineBit wallet is checked with blockchain analytics tools for links to illicit activity, such as sanctioned addresses, darknet markets, scams, ransomware or mixing services. Gift cards are checked for signs that they were stolen or bought with stolen payment details.

If a deposit or card raises concerns we may hold it while we review it, ask you questions, reject it, or report it. Where the law requires, we may be unable to return funds or tell you why.

The Travel Rule

When crypto moves between providers, rules known as the Travel Rule require information about the sender and recipient to travel with it. When you deposit from another exchange or custodial provider, we may ask that provider, or you, for information about the sender. If we cannot obtain it, we may hold or return the deposit.

Prohibited activity

You must not use BineBit to:

  • launder money, finance terrorism or evade sanctions;
  • sell crypto or gift cards that are stolen, obtained by fraud or that you have no right to sell;
  • act on behalf of someone else, or let anyone else use your account;
  • split transactions to avoid limits or checks;
  • deal in proceeds of crime, scams, gambling you are not legally allowed to take part in, or any other illegal activity.

We will close accounts involved in prohibited activity and may report them to the authorities. See our Terms of Service for what happens to funds in these cases.

Reporting to the authorities

We are legally required to report suspicious activity to the Nigerian Financial Intelligence Unit (NFIU) in Nigeria and the National Crime Agency (NCA) in the UK, and to cooperate with lawful requests from regulators and law enforcement. The law forbids us from telling anyone that a report has been made ("tipping off").

Keeping records

We keep identity records and transaction records for at least five years after our relationship with you ends, or longer where the law requires. Our Privacy Policy explains how we protect that information.

Who is responsible

Our programme is overseen by a Money Laundering Reporting Officer ([MLRO name or role]). Staff receive AML training when they join and at least once a year. The programme is reviewed regularly and tested independently.

Contact our compliance team

Questions about this policy? Email compliance@binebit.com.