KYC & AML Policy

1. Introduction

BitPulse ("we," "our," or "the Company") is a cryptocurrency exchange platform headquartered in Accra, Ghana, that enables the buying and selling of digital assets using Mobile Money services. We are committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance.

This policy has been developed in accordance with Ghana's Anti-Money Laundering Act, 2020 (Act 1044), the Anti-Terrorism Act, 2008 (Act 762), and international best practices established by the Financial Action Task Force (FATF). It outlines the measures we take to prevent the use of our platform for money laundering, terrorism financing, or other illicit financial activities.

2. Purpose and Overview

The purpose of this policy is to establish a robust framework that ensures BitPulse operates in full compliance with applicable AML and KYC regulations. Our commitment includes:

• Regular review and updating of internal AML/CTF strategies and procedures
• Maintenance of compliance with all applicable laws and regulations in Ghana
• Implementation of internal controls to detect and prevent suspicious activities
• Cooperation with relevant regulatory authorities and law enforcement agencies
• Continuous training of staff on AML/KYC obligations and emerging risks

This policy applies to all employees, officers, contractors, and third-party agents of BitPulse who are involved in the operation and management of our platform.

3. AML Compliance Officer

BitPulse has designated a qualified AML Compliance Officer who is responsible for overseeing the implementation of this policy. The officer shall have sufficient qualifications, experience, and authority to effectively carry out their duties.

Duties and Responsibilities

• Ensuring the AML/KYC programme is implemented and maintained across all operations
• Receiving and reviewing internal reports of suspicious transactions
• Filing Suspicious Transaction Reports (STRs) with the Financial Intelligence Centre (FIC) of Ghana
• Coordinating with law enforcement and regulatory bodies as required
• Organising regular training sessions for employees on AML/KYC compliance
• Maintaining and updating risk assessment frameworks to reflect evolving threats

4. Data Protection

BitPulse is committed to protecting the personal data of its users in compliance with Ghana's Data Protection Act, 2012 (Act 843). All personal information collected as part of our KYC and AML processes shall be:

• Processed lawfully, fairly, and in a transparent manner
• Collected for specified, explicit, and legitimate purposes only
• Adequate, relevant, and limited to what is necessary for compliance
• Kept accurate and up to date at all times
• Stored securely with appropriate technical and organisational safeguards
• Retained only for as long as necessary to fulfil regulatory obligations

For more information about how we handle personal data, please refer to our Privacy Policy.

5. KYC Programme

Know Your Customer (KYC) is the process by which BitPulse verifies the identity of its users to ensure that the platform is not used for illicit purposes. Our KYC programme is a cornerstone of our AML compliance framework.

5.1 Customer Acceptance Policy

BitPulse shall not establish a business relationship with any individual or entity that:

• Fails to provide satisfactory identification documents
• Provides false, misleading, or incomplete information
• Is listed on any sanctions list maintained by Ghana, the United Nations, or other relevant authorities
• Appears to be acting on behalf of an undisclosed third party
• Is under the age of 18 years

5.2 Identification Requirements

To open and maintain an account with BitPulse, users are required to provide the following identification evidence:

5.3 Ongoing Due Diligence

BitPulse conducts ongoing monitoring of all customer accounts to ensure that transaction patterns remain consistent with the customer's known profile, risk rating, and the declared source of funds. Enhanced due diligence (EDD) is applied to high-risk customers, politically exposed persons (PEPs), and transactions that exceed defined thresholds.

6. Monitoring & Suspicious Activities

BitPulse employs automated and manual monitoring systems to detect potentially suspicious transactions. Our monitoring programme includes:

• Real-time transaction monitoring with automated alerts for unusual patterns
• Periodic review of customer activity against established risk profiles
• Screening against domestic and international sanctions lists
• Analysis of transaction patterns for structuring, layering, or other typologies

Indicators of Suspicious Activity

The following activities may be considered suspicious and subject to further investigation:

• Transactions that are unusually large or inconsistent with a customer's profile
• Frequent transactions just below reporting thresholds (structuring)
• Multiple accounts operated by the same individual or from the same device
• Rapid movement of funds with no apparent economic purpose
• Reluctance or refusal to provide required identification documents
• Transactions involving jurisdictions known for high money laundering risk

7. Detection & Reporting of Suspicious Transactions

When a suspicious transaction is identified, BitPulse shall take the following actions:

• Immediately escalate the matter to the AML Compliance Officer
• Conduct a thorough investigation to determine the nature and legitimacy of the transaction
• File a Suspicious Transaction Report (STR) with the Financial Intelligence Centre (FIC) as required by law
• Suspend or restrict the relevant account pending the outcome of the investigation
• Maintain complete confidentiality of the investigation and reporting process

BitPulse strictly prohibits "tipping off" — informing any customer or third party that a suspicious transaction report has been filed or that an investigation is underway.

8. Audit Function

BitPulse maintains an independent audit function to assess the effectiveness of its AML/KYC programme. The audit objectives include:

• Evaluating compliance with this policy and applicable laws and regulations
• Testing the effectiveness of transaction monitoring and suspicious activity detection systems
• Reviewing the adequacy of employee training and awareness programmes
• Assessing the accuracy and completeness of record keeping practices
• Recommending improvements to strengthen the overall AML/KYC framework

9. Record Keeping

BitPulse maintains comprehensive records of all customer information and transaction data for a minimum period of seven (7) years from the date of the transaction or the end of the business relationship, whichever is later. Records retained include:

• Customer identification and verification documents
• Transaction records, including amounts, dates, and counterparties
• Account opening and closure documentation
• Correspondence and communications related to suspicious activity reports
• Internal investigation records and audit reports
• Employee training records and compliance certifications

10. Employee Training

All BitPulse employees receive comprehensive AML/KYC training upon hiring and on an ongoing basis thereafter. The training programme covers:

• Understanding of money laundering and terrorism financing risks and typologies
• Familiarity with Ghana's AML laws and regulatory requirements
• Recognition and reporting of suspicious transactions and activities
• Customer due diligence procedures and ongoing monitoring obligations
• Data protection and confidentiality requirements
• Internal policies, escalation procedures, and whistleblower protections

11. Administrative Sanctions

Any BitPulse employee who is found to have violated this policy or failed to comply with their AML/KYC obligations shall be subject to disciplinary action. The disciplinary process may include:

• Formal written warning
• Mandatory retraining on AML/KYC procedures
• Suspension of duties pending investigation
• Termination of employment for serious or repeated violations
• Referral to law enforcement where criminal conduct is suspected

12. Legal Penalties

Under Ghana's Anti-Money Laundering Act, 2020 (Act 1044), individuals and entities found guilty of money laundering or related offences are liable to:

• Imprisonment for a term of not less than ten (10) years and not more than twenty-five (25) years
• A fine of not less than the value of the property involved in the offence
• Forfeiture and confiscation of proceeds derived from the offence

BitPulse cooperates fully with law enforcement authorities in the investigation and prosecution of money laundering and terrorism financing offences.

13. User Obligations

By using the BitPulse platform, users agree to the following obligations:

• Provide accurate, complete, and truthful identification information at all times
• Promptly update any changes to personal information or identification documents
• Not use the platform for any illegal, fraudulent, or prohibited activities
• Cooperate fully with any verification or investigation requests from BitPulse
• Not circumvent or attempt to circumvent any security measures, transaction limits, or verification requirements

14. Conclusion

BitPulse is fully committed to maintaining the highest standards of AML and KYC compliance. We believe that a strong compliance framework not only fulfils our regulatory obligations but also builds trust and confidence among our users and the broader financial ecosystem in Ghana.

This policy is reviewed and updated at least once every two (2) years, or more frequently as required by changes in applicable laws, regulations, or business operations.