• Policies, procedures and controls are in place to meet the relevant AML/CTF statutory and regulatory requirements in the United Kingdom, Cayman Islands, USA, Luxembourg and other jurisdictions where it carries out business; 
• Internal risk control processes; 
• State the responsibilities of B2C2’s directors, officers and employees in complying with the applicable laws and regulations; 
• Promote strong corporate governance and risk management to properly manage and mitigate financial crime risks; 
• Mechanisms to ensure AML/CTF controls are implemented, maintained and operate effectively; 
• Provision of background/training on money laundering and terrorist financing to promote awareness and understanding to B2C2’s directors, officers and employees on how to recognise and report potential cases of ML/TF internally, and where required to the relevant authorities; 
• Regular reporting to the Board of Directors about the Firm’s AML/CTF efforts and progress. 
  

Whilst the Firm will, as far as is reasonably practicable, ensure consistent application of our risk based approach, we recognise that this approach cannot anticipate every eventuality. Therefore, in any given case the Chief Compliance Officer or MLRO will exercise their judgement in deciding whether or not to deviate from the written policies. Where this occurs, this judgement will be clearly reasoned and documented. 

In order to comply with the laws, regulations and guidance in the UK, Cayman Islands, EU (including B2C2 Luxembourg), the USA, and any other jurisdiction’s B2C2 operates in, B2C2 has adopted the following principles: 

• Client identities are verified in accordance with the Firm’s risk-based approach prior to conducting business with them. B2C2 has established customer due diligence (“CDD”) procedures to identify the users of its services, the natural persons who are the beneficial owner(s) and for higher-risk clients, the source of wealth and source of funds; 
• B2C2 knows its clients and understands their reasons for doing business with us, from the point of onboarding a new client and throughout the business relationship; 
• B2C2 staff are trained and made aware of both their personal legal obligations and the legal obligations of the Firm. All employees are provided with training to enable them to understand the vulnerabilities of B2C2’s business, to recognise and report suspicious activities. Training is mandatory for all employees and is carried out upon staff joining, then annually thereafter; 
• Appropriate methods of monitoring are in place to detect and report suspicious activity to the MLRO. Unexplained or abnormal transactions or activities that are suspected of being linked to criminal activity should be reported in writing to the MLRO without delay using the Internal Suspicious Transaction Reporting Form (Money Laundering). The MLRO will determine whether to report the suspicions to the relevant financial investigation unit (“FIU”), including but not limited to, the UK's National Crime Agency (“NCA”), the Cayman Island's Financial Reporting Authority ("FRA"), the Luxembourg Financial Intelligence Unit (“FIU-LUX”), or the Financial Crimes Enforcement Network (“FinCEN”) in the USA; 
• Sufficient records are kept in accordance with applicable law. B2C2 keeps records of who has been trained, the timing and form of training sessions. Records verifying client identities are retained for at least five years following the end of the business relationship. Records of relevant internal reports and disclosures made to relevant FIUs shall also be retained; and 
• The Firm will establish, maintain and implement appropriate policies and procedures in accordance with these principles. B2C2 has tailored policies and procedures in addition to controls aimed at deterring criminals from using B2C2 to launder the proceeds of crime. 
  

B2C2 must comply with the laws and regulations of the jurisdictions in which it operates. This includes: 

In the UK:

• The Proceeds of Crime Act 2002 (as amended by the Crime Courts Act 2013 and the Serious Crime Act 2015); 
• The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007); 
• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (implementing the 4th EU Money Laundering Directive); 
• The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (implementing the 5th EU Money Laundering Directive) 

In the Cayman Islands:

• The Anti-Corruption Act (2019 Revision) 
• The Penal Code (2019 Revision) 
• The Proceeds of Crime Act (2020 Revision) 
• The Terrorism Act (2018 Revision) 
• The Misuse of Drugs Act (2017 Revision) 
• The Proliferation Financing (Prohibition) Act (2017 Revision) 
• The Anti-Money Laundering Regulations (2020 Revision) 
• The International Targeted Financial Sanctions and Orders 

In the USA:

• Bank Secrecy Act and related implementing regulations
• Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA Patriot Act) and
• Anti-Money Laundering Act of 2020 

In Luxembourg:

• The Law of 12 November 2004 on the right against money laundering and terrorist financing (transposing Directive 2001/97 EC of the European Parliament) 
• The Law of the 13 February 2018 (transposing Directive (EU) 2015/849) 
• The Law of 25 of March 2020 (implementing the 5^th EU Money Laundering Directive) and
• CSSF Regulation 12-02 of 14 December 2012 (as modified by CSSF Regulation 20-05) on the fight against money laundering and terrorist financing

B2C2’s policies and procedures address related requirements in the various jurisdictions in which B2C2 operates.