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This Anti-Money Laundering (AML) Policy sets Bengalwin's framework to prevent money laundering and related financial crimes, detect illicit activity, and comply with applicable AML and countering the financing of terrorism (CFT) obligations. It applies to all Bengalwin customers, transactions, and business relationships.
The Bengalwin board holds ultimate responsibility for AML governance. An Anti‑Money Laundering Compliance Officer (AMLCO) is appointed to oversee day‑to‑day implementation and reports directly to senior management. Material amendments to this policy require approval by the board and the AMLCO prior to implementation.
Material amendments to this AML policy require formal approval from the board and the AMLCO. Notice of changes will be provided to customers consistent with regulatory obligations and internal governance requirements.
Aggregate deposits may not exceed USD 2,000. Withdrawals are disabled until Level 1 verification is completed.
Required before the first withdrawal. Collectable data include: first name, last name, date of birth, full residential address, country, and a valid email address. Data must match information held by Bengalwin's payment processors; mismatches result in blocked withdrawals and may lead to forfeit of funds.
Triggered when lifetime deposits or withdrawals exceed USD 2,000 or when a user tips another user more than USD 100. Required documents: government‑issued photo ID (front and back), a selfie holding the same ID, and proof of address. Electronic databases are queried to corroborate information. If automated checks fail, manual review is conducted and withdrawals may remain on hold.
Triggered when cumulative deposits or withdrawals exceed USD 50,000 or when a user tips more than USD 3,000. Acceptable evidence includes payslips, audited accounts, inheritance documentation, investment statements, or other documentation showing the origin of funds. The user will be notified by email and given 28 days to supply documentation; failure to comply may result in account suspension or closure. There are no upper deposit or withdrawal limits at this level.
Accurate customer identification is essential. At a minimum, Bengalwin requires a clear photo of a valid passport, national ID card, or driving licence with all corners visible and text legible, copies in Latin characters, and a selfie showing the customer holding the same document beside their face. Additional information may be requested at Bengalwin's discretion or by payment providers.
Address verification is normally conducted via two independent electronic checks. If either check fails, the customer must provide dated documents within the past three months, such as a utility bill (except mobile), a bank or credit‑card statement, or government correspondence. Documents must be high‑resolution, with all edges visible and text readable.
Bengalwin may at any time request evidence that the funds used on the platform originate from legitimate activity. Acceptable evidence includes business ownership records with relevant bank statements, recent payslips, inheritance documentation, investment statements, or other proof of origin of wealth. If a satisfactory explanation is not provided, Bengalwin may suspend or terminate the business relationship.
Bengalwin employs a risk‑based approach to AML. The company conducts an annual Enterprise‑Wide Risk Assessment (EWRA) to identify inherent AML risks across products, customer types, transaction patterns, delivery channels, and geographic reach. Ongoing transaction monitoring is conducted in two lines: first by payment processors applying AML controls at source; second by internal KYC rules to flag unusual activity. If fraud or money laundering is suspected, funds may be frozen and regulators notified.
Countries identified as high risk by international standards or by Bengalwin's regulator trigger enhanced due diligence. Customers located in or transacting from high‑risk jurisdictions are subject to additional verification and ongoing monitoring. Bengalwin reserves the right to refuse access to customers from certain restricted jurisdictions or to require additional documentation.
Bengalwin maintains an audit trail to assist financial investigations. Customer identification records are retained for at least six years after the end of the relationship. Transaction records are retained for at least ten years after execution or account closure. All records are stored securely with appropriate encryption and access controls, and documented in compliance with applicable regulatory requirements.
Customer data is protected by robust technical and organizational measures. Data will not be sold or shared with third parties except with explicit customer consent or as required by law or regulatory obligations. Bengalwin complies with applicable data protection laws and maintains appropriate data privacy safeguards.
Employees must report any grounds for knowledge or suspicion of money laundering or terrorist financing to the MLRO. Suspicious Activity Reports (SARs) are handled confidentially, and disclosure to the customer or other parties is prohibited in all circumstances to protect the integrity of investigations.
This policy may be updated to reflect changes in law, regulatory expectations, or risk assessments. Material updates require board and AMLCO approval, with customers notified in accordance with applicable regulatory requirements.
Questions or concerns regarding this AML & KYC Policy should be directed to Bengalwin's Compliance Office at [email protected].