Blink Trades LLC (hereinafter referred to as “Blink Trades”, “we”, “us” or “the Company”) is committed to preventing, detecting and not facilitating money laundering and terrorism financing activities. The Company also aims to comply with anti-money laundering (“AML”) and counter-terrorism financing (“CTF”) recommendations in a way that complements business priorities
Due to the international nature of payments and withdrawals to and from Customers the Company is required to have robust systems and controls in place to prevent the risk of money laundering (‘ML’) and terrorist financing (‘TF’), which the business could be exposed to. As a result of these internal systems and controls the Company’s its overall Financial Crime Framework and risk management framework is strengthened.
This policy outlines the process of taking the instructions from a Customer, through to the transference of funds back to the Customer, as well as how to deal with issues that can occur throughout the process.
Blackridge Capital Management Ltd. has an in-house back office department responsible for processing Customer deposits and withdrawal transaction requests.
This policy and procedures contains important information on how to deal with identified third party payments, deposit and withdrawal procedures, the checks must be conducted by the relevant teams before a withdrawal or deposit can be processed. Further, red flags are highlighted in order for all relevant employees to be aware of when dealing with Customers.
This policy along with the Anti-Money Laundering and Counter Terrorist Financing Policy and Accounts Opening Procedure form the Company’s Anti- Money Laundering and Counter Terrorist Financing Manual (‘the AML Manual’).
The Company accepts the following payment methods:
Generally, one or more of the above payment methods are always available to Customers.
There are a number of methods that are not available for Customers to fund their accounts:
Before completing a Customer’s withdrawal, the Customer account is reviewed firstly by the back- office payments team, who will carry out a number of initial checks to ensure:
The safest method of returning funds is sending them back to their source. If funds cannot be returned to the source, the Company must be satisfied that the reason is genuine (perhaps a bank account has been closed or card details have expired). The Company is cautious to ensure the destination is verified.
The Company is committed to the prevention of fraud and the promotion of an anti-fraud culture. As a result it operates a zero-tolerance attitude to fraud and requires staff to act honestly and with integrity at all times, and to report all reasonable suspicions of fraud. The Company will investigate all instances of actual, attempted and suspected fraud committed by staff, consultants, suppliers, Customers and other third parties and will seek to recover funds and assets lost through fraud. Perpetrators will be subject to disciplinary and/or legal action.
The term ‘fraud’ is commonly used to describe the use of deception to deprive, disadvantage or cause loss to another person or party. This can include theft, the misuse of funds or other resources or more complicated crimes such as false accounting and the supply of false information by employees, suppliers, consultant, Customers or any other third party.
The Company has established procedures to encourage staff to report actual, attempted or suspected fraud and/or other forms of illegal activity without fear of reprisal.
Make sure you know your red flags!
It can be difficult to detect suspicious transactions, so the Company must remain vigilant at all times. When assessing whether there is a high risk of money laundering and terrorist financing in a particular situation that also looks potentially unusual or suspicious and the extent of the measures which should be taken to manage and mitigate that risk, staff must take account of at least the following risk factors presented below.
If any the answer to any of the questions below is a ‘yes’, you must investigate further and report it to the Company’s MLRO.
Red Flag examples
A Customer uses unusual or suspicious identification documents that cannot be readily verified.
A Customer uses different National Identification Card numbers with/without variations of his or
A Customer refuses or is reluctant to provide appropriate Identification or proof of address documents.
The Customer exhibits unusual concern regarding the Company’s compliance with government reporting requirements and the Company’s AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
The information provided by the Customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
Upon request, the Customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
Does the identification document exhibit signs of fraud (tampering with the document)?
The Customer (or a person publicly associated with the Customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
For no apparent reason, the Customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
The Customer has been identified by world check as having a positive result for sanction/adverse media against their name – such as criminal activity.
The prospective Customer (natural person, director, beneficiary or beneficial owner) is
named in a government list or a credible source’s list (sanctions lists) as identified by
The Customer one who is a long-standing Customer or only undertakes occasional large transactions or small frequent transactions, which are dated widely apart?
It difficult to identify the true controlling owner of the Customer/entity from the corporate structure or there is no legitimate commercial rationale for the structure.
The Customer insists on or asks for exemptions from the Company’s policies relating to the deposits and withdrawals, such as in relation to third party transfers or transfers to an account which is the source from where the funds were originally deposited.
The Customer’s account has unexplained or sudden extensive activity, especially in accounts
that have had little or no previous activity.
The Customer/IB has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
There is an unusual pattern of transactions (payments and withdrawals) and the
transaction or transactions have no apparent economic or legal purpose?
The Customer requests that a transaction/deposit/withdrawal be processed in such a manner to
avoid the Company’s normal documentation requirements.
The Customer makes a funds deposit followed by an immediate request that the funds be wired out or transferred to a third party, or to another Company, without any apparent business purpose.
The Customer’s account shows numerous transactions/deposits aggregating to significant sums that may or may not be consistent with their financial standing/occupation/savings etc on their application form.
A business/corporate is reluctant, when establishing a new account, to provide complete information about the nature and purpose of its business, anticipated account activity, prior banking relationships, the names of its officers and directors, or information on its business location.
Customer wishes to withdraw their funds into a third-party account in someone else’s name.
Customer wishes to withdraw their funds into a new account in their name, but was not the original source of where the funds came from.
The Customer lives in a particular jurisdiction but deposits funds from another jurisdiction which is a higher risk jurisdiction to where the Customer resides.
A Customer deposits funds into several accounts, usually in amounts of less than 3,000 USD, which are subsequently consolidated into a master account and transferred outside of the country, particularly to or through a location on Money Laundering (FATF) as non-cooperative countries and territories or higher risk jurisdictions).
Funds transfer activity occurs to or from a financial secrecy haven, or to or from a higher-risk geographic location without an apparent business reason or when the activity is inconsistent with the Customer’s transaction/withdrawal or deposit history.
Customer transfers many small funds and very shortly after withdraws their funds to another bank account in another country in a manner which is inconsistent with the Customer’s history.
Large or small funds are deposited into an account or multiple accounts without any trading activity and the funds are soon withdrawn.
The currency transaction patterns show a sudden change inconsistent with normal activities and application information.
Customer makes lots of small deposits and quick withdrawals.
The stated occupation of the Customer is not commensurate with the type or level of activity.
A large number of incoming or outgoing funds transfers take place through a business/corporate account, and there appears to be no logical business or other economic purpose for the transfers, particularly when this activity involves higher-risk locations.
Foreign exchange transactions are performed on behalf of a Customer by a third party, followed by funds transfers to locations having no apparent business connection with the Customer or to higher-risk countries.
Funds are received from higher risk jurisdictions on behalf of the Customer or from the Customer’s account.
It been determined that a Customer or potential Customer is a Politically Exposed
Person, or a family member or known close associate of a PEP.
The structure of the company unusually complex with more than 3 layers of control by
The Customer has accounts in a country identified as a non-cooperative country or territory by the Financial Action Task Force (FATF) as per the country risk rating matrix.
The Customer’s account demonstrated unexplained or sudden extensive bank wire activity (deposits
and/or withdrawals), especially in accounts that had little or no previous activity.
The Customer is a company that has nominee shareholders or shares in bearer form.