AML policy

Latest update: January 01, 2024.

Virtual Assets Operator UAB (“Bankto” / “Company“) has no tolerance for money laundering, the financing of terrorism, or any other form of illicit activity, and is committed to implementing policies, procedures, and controls shaped by the best industry practices and the most effective anti-money laundering standards applied in the Republic of Lithuania and worldwide. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.


The purpose of this document is to provide a high-level overview of the Company’s AML/CTF compliance regime elements and procedures. By no means shall this document read as an entire set of all policies, procedures, and controls implemented by the Company for the prevention of money laundering, financing of terrorism, and other forms of illicit activity. This document summarizes the base points of our applicable AML/CFT policies and procedures. 


The Company operates from, and under the laws of the Republic of Lithuania. The company operates as a virtual asset operator for the exchange of virtual currency to fiat or other virtual currency and virtual currency custody. 


As such, the Company is subject to mandatory requirements that involve requirements pertaining to AML/CFT compliance and reporting obligations to the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania (“FNTT”). 


Please see the high-level summary of our principles, actions and processes related to AML/CFT.

Money Laundering Reporting Officer (MLRO)

Bankto has appointed an MLRO, who is responsible for the AML/CFT compliance within the Company. The MLRO ensures updated training and awareness and the appropriate systems and processes within the Company. Our MLRO has the education, professional suitability, abilities, personal qualities, experience, and impeccable reputation required for the performance of their duties.

Customer Due Diligence – Customer Identification and Screening

Bankto implements robust identification and verification checks, KYC processes for its business relationships and specific occasional transactions. 


Bankto carries out the following checks and implements the following procedures, among others:


  • customer and beneficial owner identification and verification of the submitted information based on robust processes, using information obtained from reliable and independent sources, including using means of electronic identification and from trust services for electronic transactions, liveness checks and video verification. 
  • understanding who the beneficial owner is, and the ownership and control structure of the business. 
  • obtaining information on the purpose and intended nature of the business relationship or transaction.​​
  • understanding and monitoring the business relationship. 
  • Bankto might require additional documents and information from customers. The refusal of clients to provide the requested documents and information to Bankto’s team may lead to suspension or termination of business relationships with Bankto.

Bankto screens all its clients, including beneficial owners, gathering information on whether a person, their family member, or a person known to be a close associate is a politically exposed person, and implementing sanction screening.  


Bankto ensures the proper and regular update of information for its clients and their activities.

Risk based approach

Bankto performs a risk-based due diligence and collects information and documentation on each prospective client in order to assess the risk profile associated. Bankto’s employees will exercise care and due diligence in determining the overall character and nature of all clients. Bankto conducts its business in accordance with the highest ethical standards and will not enter into business relationships with individuals or entities that may adversely affect its reputation and compromise the virtual currency industry.


For the purpose of identification, assessment and analysis of risks of money laundering and terrorist financing related to its activities, the Company prepares a risk assessment, taking account of the following categories: Customer risk, Geographical risk, Product risk, and Delivery channel risk.


After the risk is assessed and attributed to a particular customer, depending on the degree of risk, it should be revised periodically upon knowledge of the customer and its activity.

Transaction Monitoring

Bankto conducts ongoing monitoring of its business relationships with customers, including scrutiny of transactions carried out during the course of the relationship. This enables Bankto to ensure that the transactions are consistent with Bankto’s knowledge of the customer and the customer’s business and risk profile. Bankto undertakes reviews of existing records and ensures that documents and information remain up-to-date and adequate.

Suspicious Transactions

The Company maintains proper rules, procedures, processes, and channels for detecting, reviewing, examining, and reporting suspicious transactions. Employees are instructed to report suspicious activity to the MLRO, which is responsible for evaluating and, if deemed necessary, lodge a Suspicious Activity Report with the Financial Crime Investigation Service of Lithuania. Bankto ensures that any suspicious monetary operations or transactions are reported to the Financial Crime Investigation Service of Lithuania in accordance with the applicable laws, rules, and regulations.

Record Keeping

The Company keeps all required records pertaining to the customer, including the customer’s identification and verification data, and the relevant transactions. This is necessary for the Company to comply with its reporting obligations and other legal and regulatory requirements. The Company ensures that all records are kept in accordance with the applicable data protection laws without compromising its commitment to its AML/CFT obligations. 

Compliance and Internal Controls

The Company have established and maintains internal policies, procedures, and controls to ensure compliance with reporting obligations, ongoing monitoring, and risk assessment following AML/CFT regulations.

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