AML/CFT Policy

IT wises s.r.o. is a licensed VASP company providing cryptocurrency sales and exchange services for fiat currencies to clients across Europe. Our services are available through the itwises.com website and P2P platforms on major exchanges such as Binance, Bybit, Bitget, and OKX. We strictly comply with EU regulatory requirements and FATF recommendations, ensuring the safety and transparency of all operations.

Key Points  of the AML/CTF Policy:
1. Company Activities
Cryptocurrency Sales: We provide clients access to purchase popular cryptocurrencies such as Bitcoin, Ethereum, and Tether using modern payment methods.
Cryptocurrency-to-Fiat Exchange: Clients can convert cryptocurrency into euros through the itwisescom exchange website or P2P platforms.
Platform Versatility: Clients can conduct real-time operations using a convenient and secure interface.

2. P2P Platform Model
Partner Platforms: We collaborate with leading exchanges to enable secure P2P transactions between users.
Flexible Transactions: Clients can customize deal parameters, including amounts, currencies, and payment methods.
Verification of Participants: All users undergo rigorous KYC procedures, including checks against international sanctions lists.

3. Customer Identification (KYC)
‍All clients must complete identity verification before using our services.
‍For individuals, the following are required:
‍- Passport or ID card.
 - Proof of address (e.g., utility bill).  
- Source of income and purpose of services.
‍For legal entities, the following are required:
‍- Incorporation documents and registration number.  
- Information about beneficial owners.  
- Proof of business address and activity.
‍Special Focus:
‍- Clients are checked against EU, UN, and OFAC sanctions lists.  
- Politically Exposed Persons (PEPs) are not accepted for service.

4. Risk Management
‍Each client is assigned an individual risk profile (low, medium, high).
‍Risk-Based Approach (RBA):
Each client is assigned an individual risk profile (low, medium, high).
‍Risk Assessment Factors:
‍- Client jurisdiction.  
- Source and nature of funds.
 - Transaction history and alignment with stated purposes.
‍Enhanced Due Diligence (EDD):
Applied to high-risk clients, including additional document requests and verification of fund origins.

5. Transaction Monitoring‍Multi-level Control:
‍- Automated analysis of transactions using blockchain analytics technologies.  
- Manual review of suspicious operations by company specialists.
‍Anomaly Detection:
‍- Unusual amounts or transaction frequencies.  
- Operations involving high-risk jurisdictions.  
- Use of multiple cryptocurrency wallets in a single transaction.
‍Regular Client Activity Review:
‍- Risk profile updates every 6–12 months.  
- Data updates in response to changes in transactional behavior.

6. Sanctions Compliance
‍‍Mandatory Checks:
‍- Against EU, UN, and OFAC sanctions lists.  
- Local sanction regimes applicable in the Czech Republic.
‍Actions Upon Detection:
‍- Blocking the transaction.  
- Notifying the Financial Analytical Office (FAU).  
- Terminating business relations with the client.

7. Service Refusal
We reserve the right to refuse services in the following cases:  
‍- The client fails to provide requested information.  
- The client is linked to sanctioned individuals or jurisdictions.  
- Signs of illegal activities such as money laundering or terrorist financing are identified.

8. Data Storage and Protection
‍Client data is securely stored for 10 years after the termination of business relationships.All data is processed in compliance with GDPR and used solely for AML/CTF purposes.Regular backups and access control ensure data security against breaches and unauthorized use.

9. Employee Training
‍All company employees receive regular training on AML/CTF topics.
‍Training includes:
‍- Updates to European legislation.  
- New methods for monitoring and detecting suspicious transactions.  
- Use of analytical tools for blockchain transactions.
‍Training Frequency:
‍- Annual training for all employees.  
- Additional workshops upon AML/CTF policy updates.

10. Internal Control and Audit
‍The company has implemented a three-tier internal control system:  
1. First Line of Defense: Employees interacting with clients.  
2. Second Line of Defense: Money Laundering Reporting Officer (MLRO) and Risk Management Department.  
3. Third Line of Defense: Internal and external audits.
4. Audit Frequency: Quarterly checks with reports provided to management for addressing any discrepancies.

11. Innovative Technologies
Blockchain Analytics: Specialized tools for verifying cryptocurrency wallets for links to illicit activities.
‍Transaction Monitoring: Automated systems track all operations in real-time.
‍Artificial Intelligence: Algorithms identify anomalous transactions and flag potential risks.

12. Transparency and Regulatory Cooperation
‍All suspicious activities are promptly reported to the Financial Analytical Office (FAU).
The company actively cooperates with regulatory authorities, providing complete and accurate data upon request.

ITwises s.r.o.  is your reliable partner in the world of safe and legal cryptocurrency operations!