Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy and Procedures

It is the policy of Be Free LTD, registration number 205748672, a limited liability company incorporated and existing under the laws of Bulgaria, with registered address — Bulgaria, Sofia, 1000, Vazrajdane district, 25, Bratya Miladinovi Str., fl. 3, app. 6. (the “Company”) to prohibit and prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable legal requirements of Bulgaria.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have been derived from legitimate sources or constitute legitimate assets. Terrorist financing may not involve proceeds of criminal conduct but is rather an attempt to conceal either the origin of the funds or their intended use.

Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations, rules and laws and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The Company operates in compliance with “anti-money laundering” (“AML”) and “know your customer” (“KYC”) rules and regulations in the jurisdictions it operates in or sells products or services to, and has developed the given KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:

  • The Company performs an enterprise-wide risk assessment to determine the risk profile of the Company.
  • The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company’s Directors.

The Company shall strictly adhere to the Policy and procedures outlined herein.

The Company develops this Policy, introduces amendments and additions to it at its own discretion, and oversees compliance with its provisions and requirements.

The Company oversees:

  • ongoing compliance with the requirements introduced by the national and international laws, regulations and sanctions;
  • implementation of the risk-based “Know Your Customer” principles;
  • identifying and reporting of suspicious transactions.

For the purpose of preventing any transactions with respect to laundering of proceeds of crime the Company arranges and organizes measures required for implementation of adequate procedures in relation to monitoring the customers’ transactions, related reporting, retention of records and organization of the training activities; and ensures that any risks falling under such scope are controlled.

The Company is required to constantly monitor its level of exposure to the risk of money laundering and the financing of terrorism.

  1. “KNOW YOUR CUSTOMER” Due Diligence

    Effective Customer Due Diligence measures are essential to the management of money laundering and terrorist financing risk.

    Customer Due Diligence means identifying the customer and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with customer and on an ongoing basis. The customer identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.

    During the Customer’s registration process an individual customers provide the following identification information to the Company:

    • Customer’s full name;
    • Customer’s date of birth;
    • Country of residence/location of customer;
    • Mobile telephone number and e-mail.

    For the purposes of Customers identification, the Company requests the following documents:

    1. proof of identity:

      Personal ID verification documentary evidence of identity (must contain photograph):

      • current valid signed passport with a clear picture (expiry date should be carefully checked and be in date).

    2. proof of address (bank statement, utility bill):
      • utility bill, credit card bill (not older than 2 months);
      • bank statement containing address (not older than 2 months).

    The Company conducts the Know Your Customer (KYC) verification procedures to avoid the risk of being held liable for, and to protect itself from, a Customer attempting to use the Company for carrying out illegal activities.

    The Company is committed to protecting Customers rights and the confidentiality of their personal data. The Company collects personal information from Customers only to the extent necessary to ensure the Company is properly selling goods to Customers. Such personal information about Customers and former Customers may be disclosed to third parties only in accordance with the Company’s Personal Data Protection Policy that is designed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

    The Company shall carefully maintain Customers files, including transaction reports, receipts, notes, internal correspondence, and any other documents related to the Customer both in the electronic and paper format for a period of at least 7 (seven) years from the date of the relevant transaction.


    Suspicious transaction means presence of any information, suspicion or any matter which could arouse suspicion about the fact that the assets subject to a transaction, performed or attempted to be performed with or through the Company’s account, have been obtained illegally or are used for unlawful purposes, or are used by any terrorist organizations, terrorists or financiers of terrorism within such scope, or are related to or associated with them.

    Definition of the term “Suspicious transaction” includes use of the assets, subject to the transaction, for unlawful purposes in addition to the fact that they have been obtained illegally; and it shall purport to include prevention of financing of terrorism (even if such assets are associated with financing of terrorism) thereby.

    Grounds for determining that a specific transaction is suspicious may be personal observations and experience of the Company’s employees, as well as information received or identified.

    In accordance with the applicable law and the requirements of international organizations, the Company may, where appropriate and without the obligation of obtaining the Customer’s approval or notifying the Customer, notify regulating and/or law enforcement agencies of any suspicious transactions.

    The Company shall periodically refer to and consult the lists published by state authorities and international organizations that contain lists of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, jurisdictions that do not provide sufficient level of anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company’s Customer or potential Customer, and/or such Customer’s country of jurisdiction is included in the above lists.

    The Company shall not provide any information to any person, including the persons who are a party to the relevant transaction, other than the information provided to the supervisory staff members commissioned with the duty of supervision of the obligation, as well as to the courts during the course of any trial, that a suspicious transaction reporting has been sent or will be sent to the appropriate state authority of financial crimes investigation.

    The Company shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions’ compatibility with the Company’s knowledge of its Customers.


    Training activities are planned and organized for authorized persons of the Company as on-site (classroom learning) or off-site (e-learning programs, reminders and awareness messages) training in a manner that covers but not limited to:

    • definitions in AML,
    • the channels for reporting the suspicious transactions,
    • the concepts of laundering of proceeds of crime and financing of terrorism,
    • stages and sample cases for laundering of proceeds of crime,
    • national and international regulations with respect to prevention of laundering of proceeds of crime and financing of terrorism,
    • corporate policy and procedures of the Company,
    • principles with respect to the customer.