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Stichting Bitonic Payments
BL3P, the trading platform of Bitonic B.V., uses the Stichting Bitonic Payments. All of the customers' funds are stored and administered on the bankaccounts here. This independent foundation ensures the safety of the customer. There is no entanglement with the commercial activities of Bitonic BV (Bitonic B.V. cannot use its customer funds for any other purpose; customer funds will remain in the trust account). Should something go wrong at Bitonic B.V., your funds are guaranteed. Also, we have a special department Risk & Compliance which identifies and analyses compliance risks.
- Request license
As we hold the euros of customers on our exchange BL3P, Bitonic applied for the license of 'payment service provider' at the Dutch Central Bank (DNB). In January 2014 Bitonic started the application in collaboration with Enigma Consulting. All necessary documentation, procedures, figures, forecasts, plans and information were produced and collected in the following months. This ultimately resulted in three reports with a total of more than 400 pages. The final version was returned mid-August to DNB. In a response DNB requested a number of additional documents related to Bitcoin. These documents were handed to DNB six weeks after their reaction.
- Reaction Dutch Central Bank (DNB)
The following official response from DNB showed that Bitonic does not need a license. With this approach DNB has ensured that an exceptional position has been created. Without an official license we still can go live. With this position, combined with the formal completion of the licensing process and meeting the quality requirements, Bitonic offers reassurance to our banks. Bitonic offers comfort by applying a controlled and sound business in accordance with the requirements for a financial institution.
To maintain this comfort, Bitonic will continue to operate as a financial institution and it will impose itself the necessary requirements. Maximum protection of our customers will be ensured by the variety of measures and procedures. All obligations Bitonic imposes itself will be tested in the relationship with the banks. This will be analyzed and evaluated on a frequent basis.
The procedures followed by Bitonic are detailed in the paragraph below.
- 1. Procedure Customer Acceptance Policy
- The objective of the Bitonic Customer Acceptance Policy is to identify the customer risk-based, according to the Wwft, Art3.
Relevant laws and regulations: Law on Prevention of Money Laundering and Financing of Terrorism (Wwft), Freeze List, Politically Exposed Persons (PEP)-list.
- 2. Monitoring of transactions
The purpose of this procedure is to monitor transactions and identify suspicious activities.
Relevant laws and regulations: Law on Prevention of Money Laundering and Financing of Terrorism (Wwft), Act on Financial Supervision.
- 3. Procedure Handling complaints
This procedure ensures that people from outside the Bitonic organization, or Bitonic related persons can discuss alleged irregularities, without jeopardizing their legal position
Relevant laws and regulations: Provisions implementing Article 4:17, first paragraph of the Law on Financial Supervision Decree on the Supervision of Financial Enterprises.
- 4. Procedure Handling incidents
The purpose of the procedure Handling incidents is properly capturing tasks and responsibilities with regard to incident reporting and handling.
Relevant laws and regulations:
Rules for implementing Sections 4:11, second and third paragraphs, and 4:15, second paragraph, heading and section A of the Law Financial Supervision, Decree on the Supervision of Financial Enterprises.
- 5. Procedure Reporting Unusual Transactions
The law reporting unusual transactions calls what kind of merchants and service providers are covered by this law. Cryptocurrency traders and/or exchanges are not covered by this law and unusual transactions therefore cannot be reported.
In consultation with our banks Bitonic takes measures in certain cases to report an unusual transaction.
- 6. Procedure Freeze list
The purpose of this procedure is to capture the duties and responsibilities relating to checking if customers of Bitonic appear on the so-called "Freeze list”. If (potential) customers appear on the Freeze-list the customer relationship will be disconnected and our banking relationships will be informed.
Relevant laws and regulations: Law Sanctions 1977, Freeze list
- 7. Procedure Wallet systems
Procedures are set for transferring cryptocurrencies between different wallet systems (hot and cold wallet) in order to prevent fraud and errors. These procedures include the use of multi-signature addresses and air gaped devices.
Relevant laws and regulations: Inapplicable.
- 8. Procedure Tradebot
The tradebot monitors the BL3P order book and the order book of one or more international exchanges. This contributes to a balanced price on the exchange.
Relevant laws and regulations: Inapplicable.
- 9. Business Continuity Plan
The purpose of the Business Continuity Plan is to prepare Bitonic on events that lead to unforeseen, comprehensive service outage outside the control of Bitonic (like natural disasters), With this preparation we aim to restore services as soon as possible after an event that discontinued our business occurred.
- 10. Risk analysis BL3P
Bitonic is committed to regular and systematic analysis of relevant risks.