1. Purpose and Scope
This Financial Crime Risk Appetite Statement (the “Risk Statement”) emphasises BCB Group’s (1) commitment to combating financial crime by defining BCB’s risk appetite, risk tolerance and strategy.
Financial crime, as referred to throughout, encompasses money laundering, terrorist financing, tax evasion, proliferation financing, sanctions breaches, fraud and associated risks.
We perceive our relationships with our clients as a collaborative venture, where mutual dedication to legal compliance is key. Each client pledges to fulfil its obligations under the law, ensuring that accounts at BCB operate in strict adherence to governing statutes, regulations and robust standards.
The principles outlined in this statement apply directly to our B2C and B2B clients and indirectly to our ‘ nested customers’ in turn onboarded by our clients.
BCB has no appetite for any involvement in facilitating deliberate or knowing participation in activities that may lead to illicit behaviour or engaging in activities where potential new or increased risk exposures have not been thoroughly evaluated and mitigated before commencement.
2. Overview of Risk Appetite
BCB maintains a comprehensive financial crime management framework, which emphasises the importance of regulatory standards, professionalism, maintaining high quality staff, and accountability to stakeholders.
BCB’s risk appetite underpins both this framework and the firm’s financial crime mitigation strategy.
Financial Crime Risk Appetite Statement
BCB has a limited tolerance for financial crime risk. To this end, BCB has put in place the following mitigants and controls to prevent and detect BCB being used to facilitate financial crime:
- Financial Crime Business Wide Risk Assessment
- Financial Crime Policies and Procedures
- Client Due Diligence (“CDD”) procedures (including initial and ongoing screening)
- Transaction Monitoring (“TM”)
- AML/counter-terrorist financing (“CTF”) training for the Board and all employees
BCB Group is committed to combating financial crime and continually strives to ensure that accounts held at BCB are not misused for the purpose of financial crime irrespective of product or origination.
Our financial crime risk management controls are proportionate to the risks we face. In line with this, BCB will not:
● Knowingly facilitate criminal activities by clients, including but not limited to financial crime including tax evasion, ML, TF or any other fraudulent or illegal activity.
● Accept any deliberate or systemic breaches of applicable laws and regulation.
● Facilitate transactions with entities or individuals that:
- Cannot be identified in accordance with BCB’s KYB/KYC programme and are unresponsive to information requested by BCB which is significant to their identification or activities or intentionally provide misleading information to BCB;
- Are sanctioned or known to be associated with the financing of terrorism;
- Are known and verified to be operating without required licensing and/or registration.
● Operate any line of business or conduct business with any client segment in which the Board believes that its control environment cannot protect BCB from risks that exceed its stated tolerance.
Any high-risk clients (as determined by our Client Risk Assessment methodology) must be approved by the relevant MLRO prior to onboarding and subject to periodic reviews on an ongoing basis (existing clients). High-risk clients that do not receive approval from the MLRO must either not be onboarded, or offboarded immediately (existing clients) in accordance with BCB’s offboarding procedures.
Prohibited & Restricted Client Business Activities
Whilst BCB’s client base is focused on those entities active within the digital asset and cryptocurrency space we recognise that our clients may have use cases which involve them being active in other sectors.
BCB also recognises that some industries carry out a greater inherent financial crime risk than others. As such, BCB applies further restrictions and prohibitions depending on the industry in which clients operate.
BCB will not enter into business relationships with entities or individuals actively involved in or with strong connections to the following sectors:
● Arms and defence, such as manufacturers and distributors of military fighting vehicles, weapons, and ammunition;
● Illegal, unregulated, unlicensed, or unauthorised gambling or gaming firms;
● Unregulated or unlicensed money service businesses;
● Illegal sale or distribution of recreational drugs;
● Trafficking of cultural artefacts and/or wildlife or protected species;
● Human trafficking, modern slavery, and any other illegal activity;
● Offenders of environmental regulations and perpetrators of environmental crime;
● Adult industry.
Prohibited Transactions
BCB accounts must not be used to initiate transactions with the following characteristics:
● Payments that appear to relate to any form of illegal/unlawful activity;
● Payments sanctioned by applicable law and regulations (UN, EU, including member state, UK and US);
● Payments that are non compliant with the Funds Transfer Regulations, EU Wire Regulations (or equivalent);
● Payments that do not appear to have a legitimate purpose, including without limitation, commercial payments in repetitive, round amounts and payments lacking transparency regarding the originator and beneficiary;
● Payments related to the provision of correspondent banking services to Financial Institutions (aka, nested/downstream correspondent banking services) not approved by BCB.
(1) BCB Group (“BCB” or the “Firm”) and its subsidiaries located in various jurisdictions# are considered in the scope of this statement.
Prohibited and high risk country list
The list set out below reflects those countries BCB treat as high risk for determining whether a given relationship will be prohibited or whether EDD is required prior to onboarding or facilitating transactions.
Further additions or amendments to the list may arise depending on the risk appetite of our business partners.
| Country | Onboarding | Payments |
| Afghanistan | Prohibited | Prohibited |
| Albania | High Risk | High Risk |
| Algeria | High Risk | Prohibited |
| American Samoa | High Risk | High Risk |
| Angola | Prohibited | Prohibited |
| Anguilla | High Risk | Prohibited |
| Antigua & Barbuda | High Risk | Prohibited |
| Antilles | High Risk | High Risk |
| Argentina | High Risk | High Risk |
| Aruba (cfr NL) | High Risk | High Risk |
| Azerbaijan | High Risk | High Risk |
| Bahamas | High Risk | High Risk |
| Bahrain | High Risk | High Risk |
| Bangladesh | High Risk | High Risk |
| Barbados | High Risk | Prohibited |
| Belarus | Prohibited | Prohibited |
| Belize | High Risk | High Risk |
| Benin | High Risk | High Risk |
| Bermuda | High Risk | High Risk |
| Bolivia | High Risk | High Risk |
| Bosnia and Herzegovina | High Risk | High Risk |
| Botswana | High Risk | High Risk |
| Brazil | High Risk | High Risk |
| British Virgin Islands | High Risk | High Risk |
| Bulgaria | High Risk | Prohibited |
| Burkina Faso | Prohibited | Prohibited |
| Burundi | Prohibited | Prohibited |
| Cambodia | Prohibited | Prohibited |
| Cameroon | High Risk | Prohibited |
| Cayman Islands | High Risk | High Risk |
| Central African Republic | Prohibited | Prohibited |
| Chad | High Risk | High Risk |
| Colombia | High Risk | High Risk |
| Comoros | High Risk | High Risk |
| Cook Islands | High Risk | High Risk |
| Costa Rica | High Risk | High Risk |
| Cote D’ivoire | High Risk | Prohibited |
| Crimea & Sevastopol | Prohibited | Prohibited |
| Croatia | High Risk | Prohibited |
| Cuba | Prohibited | Prohibited |
| Curaçao | High Risk | High Risk |
| Cyprus | High Risk | High Risk |
| Democratic People’s Republic of Korea (North Korea) | Prohibited | Prohibited |
| Democratic Republic of the Congo | Prohibited | Prohibited |
| Djibouti | High Risk | High Risk |
| Dominica | High Risk | High Risk |
| Dominican Republic | High Risk | High Risk |
| Ecuador | High Risk | High Risk |
| Equatorial Guinea | High Risk | High Risk |
| Eritrea | Prohibited | Prohibited |
| Eswatini | Prohibited | Prohibited |
| Ethiopia | Prohibited | Prohibited |
| Fiji | High Risk | High Risk |
| Gabon | Prohibited | Prohibited |
| Gambia | High Risk | High Risk |
| Ghana | High Risk | Prohibited |
| Gibraltar | High Risk | High Risk |
| Grenada | High Risk | High Risk |
| Guam | High Risk | High Risk |
| Guatemala | High Risk | High Risk |
| Guernsey | High Risk | High Risk |
| Guinea | High Risk | High Risk |
| Guinea-Bissau | High Risk | High Risk |
| Guyana | High Risk | High Risk |
| Haiti | Prohibited | Prohibited |
| Honduras | High Risk | High Risk |
| Iran | Prohibited | Prohibited |
| Iraq | Prohibited | Prohibited |
| Isle of Man | High Risk | High Risk |
| Jamaica | High Risk | High Risk |
| Jersey | High Risk | High Risk |
| Jordan | High Risk | High Risk |
| Kazakhstan | High Risk | High Risk |
| Kenya | High Risk | Prohibited |
| Kiribati | High Risk | High Risk |
| Kyrgyzstan | High Risk | High Risk |
| Laos | Prohibited | Prohibited |
| Lebanon | Prohibited | Prohibited |
| Lesotho | High Risk | High Risk |
| Liberia | High Risk | High Risk |
| Libya | Prohibited | Prohibited |
| Liechtenstein | High Risk | High Risk |
| Macau | High Risk | High Risk |
| Madagascar | High Risk | High Risk |
| Maldives | High Risk | High Risk |
| Mali | Prohibited | Prohibited |
| Marshall Islands | High Risk | High Risk |
| Mauritania | High Risk | High Risk |
| Mauritius | High Risk | High Risk |
| Mexico | High Risk | High Risk |
| Micronesia | High Risk | High Risk |
| Moldova | High Risk | High Risk |
| Monaco | High Risk | Prohibited |
| Mongolia | Prohibited | Prohibited |
| Montenegro | High Risk | High Risk |
| Montserrat | High Risk | High Risk |
| Morocco | High Risk | Prohibited |
| Mozambique | Prohibited | Prohibited |
| Myanmar | Prohibited | Prohibited |
| Namibia | High Risk | Prohibited |
| Nauru | High Risk | High Risk |
| Nepal | High Risk | Prohibited |
| Nicaragua | Prohibited | Prohibited |
| Niger | Prohibited | Prohibited |
| Nigeria | Prohibited | Prohibited |
| Niue | High Risk | High Risk |
| Pakistan | High Risk | Prohibited |
| Palau | High Risk | High Risk |
| Palestine | Prohibited | Prohibited |
| Panama | High Risk | Prohibited |
| Papua New Guinea | High Risk | High Risk |
| Paraguay | High Risk | High Risk |
| People’s Republic of China | Prohibited | Prohibited |
| Peru | High Risk | High Risk |
| Philippines | High Risk | Prohibited |
| Puerto Rico | High Risk | High Risk |
| Russia | Prohibited | Prohibited |
| Rwanda | High Risk | High Risk |
| Saint Kitts and Nevis | High Risk | High Risk |
| Saint Lucia | High Risk | High Risk |
| Saint Vincent and the Grenadines | High Risk | High Risk |
| Samoa | High Risk | High Risk |
| Sao Tome and Principe | High Risk | High Risk |
| Senegal | High Risk | Prohibited |
| Serbia | High Risk | High Risk |
| Seychelles | High Risk | High Risk |
| Sierra Leone | Prohibited | Prohibited |
| Solomon Islands | High Risk | High Risk |
| Somalia | Prohibited | Prohibited |
| South Africa | High Risk | Prohibited |
| South Sudan | Prohibited | Prohibited |
| Sri Lanka | High Risk | High Risk |
| Sudan | Prohibited | Prohibited |
| Suriname | High Risk | High Risk |
| Syria | Prohibited | Prohibited |
| Tajikistan | High Risk | High Risk |
| Tanzania | High Risk | Prohibited |
| Timor-Leste | High Risk | High Risk |
| Togo | High Risk | High Risk |
| Tonga | High Risk | High Risk |
| Trinidad and Tobago | High Risk | High Risk |
| Tunisia | High Risk | High Risk |
| Turkey | High Risk | High Risk |
| Turkmenistan | High Risk | High Risk |
| Turks and Caicos Islands | High Risk | High Risk |
| Tuvalu | High Risk | High Risk |
| Uganda | Prohibited | Prohibited |
| Ukraine | High Risk | Prohibited |
| United Arab Emirates | High Risk | High Risk |
| US Virgin Islands | High Risk | Prohibited |
| Uzbekistan | High Risk | High Risk |
| Vanuatu | High Risk | Prohibited |
| Venezuela | Prohibited | Prohibited |
| Vietnam | High Risk | Prohibited |
| Yemen | Prohibited | Prohibited |
| Zambia | High Risk | High Risk |
| Zimbabwe | High Risk | Prohibited |
