BitLeague LLC and affiliates (hereinafter “we”) have established
and implemented an Anti-Money Laundering, Anti-Terrorist
Financing, and Trade & Economic Sanctions Program
(“AML/ATF/Sanctions Program” or “Program”) to ensure a robust and
compliant digital asset trading platform. We want to promote
legal, transparent business activities and maintain a strong
reputation among our customers, regulators, and the digital asset
2. OUR ROLE AND ACTIVITIES
We are a global digital asset trading platform or marketplace,
where traders come as buyers and sellers (commonly referred as
market-makers and market-takers). For clarity, buyers and sellers
trade with each other and not with BitLeague LLC and affiliates.
We are not a counterparty to any trade. Our Services are available
through BitLeague LLC and affiliates, associated application
program interfaces and/or mobile applications. In addition, Users
may purchase term deposit products and collateral lending products
on our Site.
3. REGULATORY LANDSCAPE
We understand that regulatory bodies have taken a diverse approach
to the laws and regulations regarding digital assets. As a trading
platform, we believe that Bitcoin is a digital asset that is
emerging as an innovative alternative asset class; and therefore,
digital assets should not be called currency or money.
Disclosure: Digital assets are not fiat money nor fiat currency.
Digital assets such as Bitcoin are NOT backed by any government or
central bank. Nevertheless, since we provide a valuable feature to
our customers who wish to trade and settle in fiat, we believe it
is imperative to maintain a robust AML/ATF/Sanctions program as we
connect with the fiat financial system. We may at times have
opinions of the different regulatory approaches taken by various
government bodies; however, at all times, we will fully abide by
rules and regulations of the respective countries we operate in;
mainly, the United States. We regularly reach out to regulators
and industry on the best approach to regulating digital asset
businesses. Furthermore, BitLeague LLC and affiliates do not
accept certain customers. To maintain our strong reputation in the
market and ensure a robust compliant marketplace, we have decided
to not seek nor accept customers from certain jurisdictions
including any jurisdiction which has US Sanctions imposed on it.
We cooperate with governments and respect regulations and comply
with applicable regulations. As good corporate citizens, we may be
asked for information from law enforcement authorities and will
assist if permissible by law as law enforcement conduct
investigations to pursue and thwart illicit activity. What this
also means is that our platform is intended for law abiding
customers. We welcome the opportunity to earn your business, and
in return we require that you act legally and properly on our
4. OUR AML/ATF PROGRAM
We have designed our Program to reasonably prevent money
laundering and terrorist financing through a risk-based,
multi-layer control system.
The first layer includes a stringent customer identification
program, including verifying the identity of our customers,
whether individuals or entities. In addition to obtaining
identification documents, we obtain for non-natural persons their
entities’ beneficial owners/natural persons consistent to
international standards such as the Financial Action Task Force
The second layer includes a risk-based system to warrant
additional customer due diligence. To accomplish this, we screen
our customers (including beneficial owners) against the
entities/persons on the United States Office of Foreign Assets
Control (OFAC) Sanctions Lists, and the United Nation Security
Council Sanctions List, among other government-provided lists of
sanctioned individuals and entities. We also may screen against
other lists on a discretionary basis to protect our reputation and
The third layer includes ongoing monitoring for suspicious
activity. If our Program suspects or has reason to suspect
suspicious activities have occurred, we will file suspicious
activities reports with local regulators. A suspicious transaction
is often inconsistent with a customer’s known and legitimate
business, or personal activities.
These are the primary components of our compliance program;
however, the most important glue or connection to these layers are
our leadership team and staff, including AML/Risk personnel that
execute training, oversight and a sound compliance culture.
Trading in digital assets is considered high risk. Digital assets
such as Bitcoin are NOT backed by any government or central bank.
The risk of loss in trading or holding digital assets can be
substantial. You should carefully consider whether interacting,
holding, or trading digital assets is suitable for you in light of
your financial condition.
If you have questions or require assistance with our customer due
diligence controls, please reach out to our 24/7 customer service
representatives by email at email@example.com.