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.

 

 

Onboarding Country TM
Prohibited Afghanistan Prohibited
High Risk Albania High Risk
High Risk Algeria Prohibited
High Risk American Samoa High Risk
Prohibited Angola Prohibited
High Risk Anguilla Prohibited
High Risk Antigua & Barbuda Prohibited
High Risk 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 Prohibited
Prohibited Belarus Prohibited
High Risk 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 Prohibited
Prohibited Burkina Faso Prohibited
Prohibited Burundi Prohibited
Prohibited Cambodia Prohibited
High Risk Cameroon Prohibited
High Risk Cayman Islands High Risk
Prohibited Central African Republic Prohibited
High Risk 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 Prohibited
High Risk Croatia Prohibited
Prohibited Cuba Prohibited
High Risk Curaçao High Risk
High Risk Cyprus High Risk
Prohibited Democratic People’s Republic of Korea (North Korea) Prohibited
Prohibited Democratic Republic of the Congo Prohibited
High Risk 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
Prohibited Eritrea Prohibited
Prohibited Eswatini Prohibited
Prohibited Ethiopia Prohibited
High Risk Fiji High Risk
Prohibited Gabon Prohibited
High Risk Gambia High Risk
High Risk Ghana Prohibited
High Risk 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
Prohibited Haiti Prohibited
High Risk Honduras High Risk
Prohibited Iran Prohibited
Prohibited Iraq Prohibited
High Risk 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 Prohibited
High Risk Kiribati High Risk
High Risk Kyrgyzstan High Risk
Prohibited Laos Prohibited
Prohibited Lebanon Prohibited
High Risk Lesotho High Risk
High Risk Liberia High Risk
Prohibited Libya Prohibited
High Risk Liechtenstein High Risk
High Risk Macau High Risk
High Risk Madagascar High Risk
High Risk Maldives High Risk
Prohibited Mali Prohibited
High Risk 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 Prohibited
Prohibited Mongolia Prohibited
High Risk Montenegro High Risk
High Risk Montserrat High Risk
High Risk Morocco Prohibited
Prohibited Mozambique Prohibited
Prohibited Myanmar Prohibited
High Risk Namibia Prohibited
High Risk Nauru High Risk
High Risk Nepal Prohibited
Prohibited Nicaragua Prohibited
Prohibited Niger Prohibited
Prohibited Nigeria Prohibited
High Risk Niue High Risk
High Risk Pakistan Prohibited
High Risk Palau High Risk
Prohibited Palestine Prohibited
High Risk Panama Prohibited
High Risk Papua New Guinea High Risk
High Risk Paraguay High Risk
Prohibited People’s Republic of China Prohibited
High Risk Peru High Risk
High Risk Philippines Prohibited
High Risk Puerto Rico High Risk
Prohibited Russia Prohibited
High Risk 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 Prohibited
High Risk Serbia High Risk
High Risk Seychelles High Risk
Prohibited Sierra Leone Prohibited
High Risk Solomon Islands High Risk
Prohibited Somalia Prohibited
High Risk South Africa Prohibited
Prohibited South Sudan Prohibited
High Risk Sri Lanka High Risk
Prohibited Sudan Prohibited
High Risk Suriname High Risk
Prohibited Syria Prohibited
High Risk Tajikistan High Risk
High Risk Tanzania Prohibited
High Risk 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
Prohibited Uganda Prohibited
High Risk Ukraine Prohibited
High Risk United Arab Emirates High Risk
High Risk US Virgin Islands Prohibited
High Risk Uzbekistan High Risk
High Risk Vanuatu Prohibited
Prohibited Venezuela Prohibited
High Risk Vietnam Prohibited
Prohibited Yemen Prohibited
High Risk Zambia High Risk
High Risk Zimbabwe Prohibited