1. BACKGROUND

These Know Your Customer (“KYC”) Policy and Anti Money Laundering (“AML”) Measures (together referred to as the “Policy”) are established to facilitate the development of controls that will aid in the detection and prevention of money laundering using the services of ballewtrade.com., a company duly registered in United States with registered address: 4800 I-55 North, Suite 21 Jackson, MS 39211, United States (hereinafter referred as “ballewtrade.com”), a funds management company with global client base and focused on creating a stable and long-term multi-level-marketing, which does not exclude anybody, doesn’t matter from which country, which level of society or from which financial background somebody comes. It is the intent of ballewtrade.com to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.

2. OBJECTIVES OF THE POLICY

2.1 To lay down policy framework for abiding by the Know Your Customer Norms and Anti Money Laundering Measure as set out by appropriate authorities, based on the recommendations of the Financial Action Task Force (FATF) and the paper issued on Customer Due Diligence (CDD).
2.2 The objective of the Policy is to prevent ballewtrade.com being used intentionally or unintentionally, by criminal elements for money laundering activities.
2.3 To enable the ballewtrade.com to know/understand its customers and their financial dealings better, which in turn would help it to manage its risks prudently.
2.4 To lay down explicit criteria for acceptance of customers.
2.5 To establish procedures to verify the bona-fide identification of individual/corporate customers.
2.6 To establish processes and procedures to monitor high value transactions and/or transactions of suspicious nature.
2.7 To develop measures for conducting due diligence in respect of customers and reporting of such transactions.
2.8 To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws/laid down procedures and regulatory guidelines.
2.9 To comply with applicable law and regulatory guidelines
2.10 To take necessary steps to ensure that the relevant staff are adequately informed and trained in KYC/AML procedures.
2.11 To manage the risk associated with dealing with customers who are potentially in contravention of KYC and AML norms.

3. SCOPE OF THE POLICY

This policy applies to any irregularity, or suspected irregularity, involving ballewtrade.com’s customers, employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with ballewtrade.com. Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the ballewtrade.com.

4. KYC POLICY

There are four key elements to the KYC guidelines:

4.1 Customer Acceptance Policy;
4.2 Customer Identification Procedures;
4.3 Monitoring of Transactions; and 4.4 Risk Management ballewtrade.com’s KYC policy regarding the four key elements in respect of the customers is given below.

5. CUSTOMER ACCEPTANCE POLICY (CAP)

ballewtrade.com’s Customer Acceptance Policy, which lays down explicit criteria for acceptance of customers, ensures the following aspects of the customer relationship:
5.1 ballewtrade.com’s customers/clients are mainly individuals and corporations to whom ballewtrade.com provides financial management services. These are generally individual persons.
5.2 ballewtrade.com shall not deal with anonymous or fictitious name(s) person having connections with terrorist’s organization(s).
5.3 It shall be ensured that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorist or terrorist organizations.
5.4 It would be necessary on the part of customer to furnish data/documents as prescribed in this policy. In case of non-submission of information or non-submission of documents as required, ballewtrade.com may even suspend such customer account.
5.5 Customers shall be accepted after verifying their identity as laid down in customer identification procedures. Documentation requirements and other information shall be collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of applicable laws.
5.6 The documentation requirements to be obtained from the customers would be reviewed by Compliance Officer from time to time based on emerging business needs and guidelines issued by regulatory authorities.

6. CUSTOMER IDENTIFICATION PROCEDURE (CIP)

6.1 Customer identification means identifying the customer and verifying his/her identity by using reliable, independent source documents, data or information.
6.2 ballewtrade.com shall obtain sufficient information necessary to verify the identity of each new customer, whether regular or occasional.
6.3 Customer Identification Procedure to be carried out at different stages: while carrying out a financial transaction (or), when there is a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.
6.4 For customers that are natural persons, it would be necessary to verify the identity of the customer, his address/location.
6.5 For customers that are legal persons or entities, it would be necessary to
(i) verify the legal status through proper and relevant information consigning the account
(ii) verify that any person purporting to act on behalf of the legal person/ entity is so authorized and identify and verify the identity of that person
(iii) understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person

7. MONITORING OF TRANSACTIONS

7.1 Monitoring of transactions will be conducted taking into consideration the risk profile of the account. ballewtrade.com shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified.
7.2 To ensure monitoring of ballewtrade.com’s KYC Guidelines, the investor/user may be requested to resubmit their E currency wallet (Bitcoin) as requested by ballewtrade.com from time to time to make sure they are all updated with the company account.
7.3 To ensure monitoring and reporting of all transactions and sharing of information as required under the law for KYC, any officer of the ballewtrade.com duly authorized is designated as Principal Officer for KYC. By default, Managing Director (“MD”) is the Principal Officer for KYC.

8. RISK MANAGEMENT

8.1 ballewtrade.com may expose to the following risks which arise out of Money Laundering activities and non-adherence of KYC standards.
a) Reputation Risk: Risk of loss due to severe impact in ballewtrade.com’s reputation which requires the confidence of customers, investors, and the general marketplace.
b) Compliance Risk: Risk of loss due to failure of compliance with key regulators governing the business operations.
c) Operational Risk: Risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events.
d) Legal Risk: Risk of loss due to any legal action ballewtrade.com or its staff may face due to failure to comply with the law.
8.2 ballewtrade.com shall ensure that adequate measures are taken to cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility should be explicitly allocated for ensuring that ballewtrade.com’s policies and procedures are implemented effectively.
8.3 ballewtrade.com if required may categorize the customers according to the risk perceived to facilitate undertaking due diligence for the purpose of risk categorization.
8.4 For the purpose of effective implementation of KYC policy and AML Standards, the Principal Officer shall monitor transactions on need basis with IT support to meet the requirements of KYC policy and AML standards.
8.5 All transactions of suspicious nature shall be reported to Principal Officer as an when the transactions are found to be suspicious by the staff. The Principal Officer shall ensure that such reporting system is in place and shall monitor receipt of the reports.
8.6 The Principal Officer designated by ballewtrade.com in this regard will have overall responsibility for maintaining oversight and coordinating with various functionaries in the implementation of this Policy.
8.7 Suitable checks and balances in this regard will be put in place at the time of introducing new products/procedures as also at the time of review of existing products/ procedures for overall risk and compliance management.

9. AML MEASURES

All necessary information in respect of transactions which takes place between customers and ballewtrade.com has to be maintained properly, to permit reconstruction of individual transaction, including the following information:

a) the nature of the transaction;
b) the amount of transaction
c) the date on which the transaction was conducted; and
d) the parties to the transaction

10. MAINTENANCE AND PRESERVATION OF RECORD

10.1 ballewtrade.com shall have a system for proper maintenance and preservation of information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.
10.2 ballewtrade.com would maintain all transaction records for 50 years from the date of transactions between the customers and ballewtrade.com.
10.3 ballewtrade.com will also ensure that records pertaining to the identification of the customer and his/her address (e.g. copies of documents like email, wallet adresses etc.) obtained while opening the account and during the course of business relationship, are properly preserved for at least fifty years after the business relationship is ended. The identification records and transaction data will be made available to the competent authorities upon request.

11. REPORTING

ballewtrade.com shall be required to report information relating to suspicious transactions to the Financial Crimes Enforcement Network (“FinCEN”). A Suspicious Activity Report (SAR) is a document that financial institutions must file with the FinCEN following a suspected incident of money laundering or fraud.

12. CUSTOMER EDUCATION

12.1 ballewtrade.com shall take adequate measures to educate the customer on the objectives of the KYC program, especially at the time of obtaining sensitive or personal information from the customers.
12.2 While dealing with customers, Staff in ballewtrade.com shall take special care in obtaining required information from the customers.
12.3 Policy along with relevant forms shall be uploaded in ballewtrade.com’s Website to educate the customer of the objectives of the KYC program.
12.4 ballewtrade.com shall also take care to see that implementation of the KYC guidelines in respect of customer acceptance, identification etc. do not result in denial of services to genuine customers/general public.


13&14 POLICY UPDATES AND REVIEW

14.1 The modifications/updates to the Policy shall be initiated by ballewtrade.com as per business requirements keeping in view the new guidelines on KYC/AML or based on feedback/inputs received from customer and staff.
14.2 The modifications/updates to the policy may also be initiated by Compliance Officer based on the analysis of transactions monitored in customer accounts/operational risk events. The same shall be put up for approval to the Board.
14.3 The Policy shall be reviewed annually or as and when considered necessary by the Board.

15. EMPLOYEE RESPONSIBILITIES

All employees of ballewtrade.com have a responsibility to act honestly and to diligently follow the procedures and controls that have been implemented to mitigate fraud, theft and corruption. They must not bypass or avoid using those procedures or controls. They must immediately report identified weaknesses or loopholes in controls that could facilitate a fraud. They must also report immediately any incident of fraud, theft or corruption, whether it is suspected or actual, either to their line manager or by following the procedures laid down. This responsibility also applies to instances of customer misconduct which may come to the attention of staff.

16. CUSTOMER PROTECTION

16.1 ballewtrade.com's Customer Due Diligence program collects certain identity details at sign-up while remaining relatively frictionless. Once certain thresholds are met, in compliance with relevant market regulation, ballewtrade.com will subject users to additional KYC requirements for identity verification.
16.2 ballewtrade.com conducts a global AML/CTF and Sanctions risk assessment consistent with Financial Action Task Force (FATF) guidance to identify, assess and understand the ML/TF risks ballewtrade.com faces. This is consistent with a risk-based approach (RBA) which impacts global policy decision-making and implementation of program elements.
16.3 ballewtrade.com screens accounts and transaction history on a nightly basis, covering the entire customer base. We cross-reference our information against a variety of lists from regulators, governments and more (OFAC's Specially Designated Nationals list, UN Security Council sanctions list, Commission de Surveillance du Secteur Financier in the EU, etc.)

17. CYBERCRIME

17.1 ballewtrade.com is proactive about Cybercrime.
17.2 ballewtrade.com engages/partners with law enforcement proactively and reactively to both help stop cybercrime while also catching the bad actors that have committed crimes and are under investigation.
17.3 ballewtrade.com has proactively reached out to law enforcement to make them aware of this system and encourage them to reach out to us with any questions or concerns.
17.4 ballewtrade.com collaborates with various teams across the company (compliance, legal, risk, information security, etc.) to better identify potential bad actors and make recommendations to law enforcement organizations.