Anti-Money Laundering (AML) Policy

Last updated: 01. August 2024

Preamble

In commitment to upholding voluntary regulatory compliance as mandated by Swiss legislation and the principles set forth by the Financial Action Task Force (FATF), Incentiwave AG (also "CLICKBIT") operates the portal through https://clickbit.cash (the “Portal”) and adopts this Anti-Money Laundering Policy ("Policy"). When using the Portal, the following documents must also be taken into account: Terms of Use (https://clickbit.cash/terms-of-use), Privacy Policy (https://clickbit.cash/privacy-policy) and Risk Disclaimer (https://clickbit.cash/risk-disclaimer).

This Policy is binding and comes into effect upon adoption, governing all activities of Incentiwave AG employees and users of the Portal, except as explicitly exempted by law.

Policy Statement

This Policy stands to ensure voluntary adherence to the Swiss Anti-Money Laundering Act (AMLA) and embraces the international standards established by the FATF.

Identification

The Portal undertakes stringent customer due diligence (CDD) procedures, requiring the collection and verification of valid identification for all users. This process includes obtaining and validating necessary documentation to confirm the identities of users and the beneficial owners before facilitating any investment transactions on the Portal.

Due Diligence and Risk Assessment

Incentiwave AG determines the nature and purpose of the business relationship requested by the user. In certain cases, Incentiwave AG also clarifies the economic background and the purpose of a transaction or of a business relationship. Among other things, Incentiwave AG conducts thorough risk assessments to identify and address potential money laundering threats, with a particular focus on high-risk categories such as Politically Exposed Persons (PEPs) and entities from jurisdictions considered high risk. Enhanced due diligence is conducted as required.

Monitoring and Reporting

Continuous monitoring of all transactional activity for signs of irregularities is in place, alongside an imperative to report any suspicious transactions to the relevant authorities confidentially and promptly, in line with legal obligations.

Record Keeping

Incentiwave AG maintains detailed and comprehensible records of customer identification, transaction data, and reporting logs for a legally mandated duration.

Customer Acceptance Policy

The Portal establishes clear criteria for user acceptance, strictly prohibiting engagements with anonymous or pseudonymous individuals or entities. Incentiwave AG reserves the right to reject any user, payment or business that is not consistent with this Policy and the requirements of the applicable laws and regulations.

Organizational Measures

An ongoing training program is in place to ensure that all Incentiwave AG employees are well informed about AML regulations and internal policies, with a particular focus on identifying and managing potentially suspicious financial activities.

Confidentiality and Data Protection

The Portal ensures the protection and confidentiality of customer information, adhering strictly to data protection statutes and employing advanced cybersecurity protocols. Further information can be found in the Privacy Policy of Incentiwave AG (https://clickbit.cash/privacy-policy).

Technology and Tools

Incentiwave AG utilizes state-of-the-art technology to enhance the monitoring and analysis of transactions for AML risks.

Ethics and Conduct

An uncompromising ethical code dictates the reporting of any and all suspicious money laundering activities immediately.

Penalties for Non-Compliance

A framework for disciplinary measures addresses instances of non-compliance with the AML policy by Incentiwave AG employees.

Third-Party and Partner Due Diligence

Diligent reviews of all third-party affiliations and partnerships ensure alignment with AML standards reflective of those upheld by Incentiwave AG.

Policy Review and Update

Incentiwave AG reviews and updates this Policy from time to time at sole discretion to reflect ongoing changes in law or regulatory requirements and the dynamic environment of financial regulation.

Enacted in Zug, Switzerland, by the governance body of Incentiwave AG Verein.