Terms and Conditions
BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM:
TheCoinBros, LLC (“we” or “our”) A registered money service business (MSB) has developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) for our digital asset ATM/BTC service in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in the United States and other countries where we conduct business. This includes, but is not limited to:
Establishing robust internal policies, procedures and controls that combat any attempted use of TheCoinBros BTM’s for illegal or illicit purposes and that are designed to ensure our customers basic protections under consumer protection laws;
Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
- iling Suspicious Activity Reports (“SARs”);
- Filing Currency Transaction Reports (“CTRs”);
- Maintaining comprehensive records of orders and other transfers;
Employing a Chief Compliance Officer (“CCO”Myself) to act as our Bank Secrecy Act Officer and be responsible for the implementation and oversight of our BSA/AML Program;
Executing Know Your Customer (“KYC”) procedures on all customers;
- Performing regular, independent audits of our BSA/AML Program;
- Following record retention requirements; and
Implementing a formal and ongoing compliance training program for all new and existing employees.
POLICIES AND PROCEDURES:
Our BSA/AML Program has been reviewed and approved by our compliance and legal department. Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations and policies. We are regulated by the California State Department of Financial Services and our BSA/AML Program is subject to its review and approval.
We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, as well as other reporting requirements and audits.
Our CCO (Jessica Murphy) is responsible for developing and enforcing the policies and procedures of our BSA/AML Program. Our CCO is required to report any violations of our BSA/AML Program directly to our CEO and our Board. In addition, our CCO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually
Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.
All individual customers are subject to these MSB/AML rules and regulations and agree to the terms before payment.
- If the customer transaction is below $901, Verified SMS + First and Last Name
- If the customer transaction is above $901; Verified SMS + Government Issued ID (Front & Back)
TheCoinBros, LLC. ATM’s retains to right to attempt to collect, verify, and authenticate all OR some of the following information:
- Email address;
- Mobile phone number;
- Date of birth (“DOB”);
- Proof of identity (e.g. driver’s license, passport or government-issued ID);
- Home address (not a mailing address or P.O. Box); and
- Additional information or documentation at the discretion of our Compliance Team.
- Non-US Customers are subject to the same requirements.
SUSPICIOUS ACTIVITY / CURRENCY TRANSACTION REPORTS:
We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on TheCoinBros, LLC. ATM’s. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, (Jessica Murphy) which performs transaction monitoring to help identify unusual patterns of customer activity. Our CCO (Jessica Murphy) reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.
In addition, all currency transactions over a determined USD value ($10,000) are be reported to FinCEN via a CTR filing.
Our CCO (Jessica Murphy) maintains records and supporting documentation of all SARs and CTRs that have been filed.
All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.
BSA / AML PROGRAM AUDIT INTERNAL:
TheCoinBros,LLC. is responsible for audits of our BSA/AML Program at least annually, as well as independent reviews and presenting those results to our President (Cory Capaldi)