Anti-Money Laundering (AML) Policy

The AML Policy is designed to establish the essential standards designed to prevent Bytes and Barter Global Services Ltd (hereinafter called ", Company") from being used for money laundering and terrorism financing.

This AML Policy sets out the minimum standards which must be complied with and includes:

  • Establishing and maintaining a Risk-Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees

What do We do with Your personal information in connection with AML Policy ? reserves all right to share any information in its possession with any relevant third party, as soon as LumierExchange has a reasonable doubt about a suspicious activity in relation with Money Laundering or Terrorism Financing. Following, your personal information is disclosed to third parties providing fraud prevention, fraud screening and age and/or identity verification services Us.

For this purpose, your personal information including your full name and address, your bank account, gender and contact telephone numbers may be used for fraud prevention, fraud screening and age and identity verification purposes. In this regards, your personal information may be disclosed to and used by fraud prevention agencies (“FPAs”) for all such purposes and those agencies may keep a record of it where permitted by applicable data protection laws.

You should not confirm Your order or tick the relevant box on Our Website unless You consent to this use of Your personal information.

As part of this, We may check the following records about You:

  • Our own records;
  • Records held by third parties providing services to us;
  • Records at fraud prevention agencies (FPAs).

The checks described above may include assessing and verifying identities to prevent and detect fraud. The information We obtain from third parties providing services to Us and FPAs will help Us to decide whether we are willing to accept orders and/or payments from You through our Website and whether to complete the order and/or payment process through Our Website.

As explained above, personal information about You may be sent by Us to FPAs and recorded by them. In addition, We may give details of the orders and/or payments You make to FPAs. All such information may be supplied by the FPAs to other organisations in order that they may perform similar fraud prevention, fraud screening and age and identity verification checks against You, including as part of online transactions and otherwise.

If You give us false or inaccurate personal information about Yourself and /or if We have a reasonable doubt about a suspicious activity in relation with Money Laundering or Terrorism Financing and / or if We suspect fraudulent orders and/or fraudulent payments and/or identity fraud, we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention. We and other organisations may access and use information which relates to You and which is recorded by FPAs in other countries.

Except the above, we will not share Your personal information with any government agency, unless required to do so by law.

This section constitutes a short form explanation about how Your personal information may be used by Us in conjunction with the AML Policy and the FPAs.

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