Buroka Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to
prevent and mitigate possible risks of Buroka being involved in any kind of illegal activity.
Both international and local regulations require Buroka to implement effective internal procedures and mechanisms
to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass
destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
AML/KYC Policy covers the following matters:
1. Verification procedures.
2. Compliance Officer.
3. Monitoring Transactions.
4. Risk Assessment.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According
to CDD, Buroka establishes its own verification procedures within the standards of anti-money laundering and
“Know Your Customer” frameworks.
Buroka’s identity verification procedure requires the User to provide Buroka with reliable, independent source
documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For
such purposes Buroka reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
Buroka will take steps to confirm the authenticity of documents and information provided by the Users. All legal
methods for double-checking identification information will be used and Buroka reserves the right to investigate
certain Users who have been determined to be risky or suspicious.
Buroka reserves the right to verify User’s identity in an on-going basis, especially when their identification
information has been changed or their activity seemed to be suspicious (unusual for the particular User). In
addition, Buroka reserves the right to request up-to-date documents from the Users, even though they have passed
identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly in accordance with the
Once the User’s identity has been verified, Buroka is able to remove itself from potential legal liability in a
situation where its Services are used to conduct illegal activity.
The Users who are intended to use payment cards in connection with the Buroka’s Services have to pass card verification
in accordance with instructions available on the Buroka’s Site.
The Compliance Officer is the person, duly authorized by Buroka, whose duty is to ensure the effective implementation
and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects
of Buroka’s anti-money laundering and counter-terrorist financing, including but not limited to:
a. Collecting Users’ identification information. b. Establishing and updating internal policies and procedures
for the completion, review, submission and retention of all reports and records required under the applicable
laws and regulations. c. Monitoring transactions and investigating any significant deviations from normal activity.
d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms
and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under
the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money
laundering, terrorist financing and other illegal activity.
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their
transactional patterns (what they do). Therefore, Buroka relies on data analysis as a risk-assessment and suspicion
detection tool. Buroka performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping,
investigation management, and reporting. System functionalities include:
1) Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points,
placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal
communications and filling out statutory reports, if applicable;
2) Case and document management.
With regard to the AML/KYC Policy, Buroka will monitor all transactions and it reserves the right to:
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis
in order to define whether such transactions are to be reported and treated as suspicious or are to be treated
as bona fide.
Buroka, in line with the international requirements, has adopted a risk-based approach to combating money laundering
and terrorist financing. By adopting a risk-based approach, Buroka is able to ensure that measures to prevent
or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow
resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance
with priorities so that the greatest risks receive the highest attention.