Compliance and AML

Our approach

BAJJPAY provides liquidity only to businesses and professional counterparties that have been verified. Compliance is built into the way the desk works: every organisation is verified before its first trade, every settlement passes a compliance review before funds are released, and every action is recorded. This page describes that process so that clients know what to expect.

Onboarding

Before an organisation can trade, BAJJPAY verifies the entity, its ownership and control, and the people who will act for it. The organisation's business profile is completed in the portal and its documents are uploaded there, where they are reviewed by the desk. The organisation is approved to trade only once that review is complete. Terms, limits and settlement instructions are agreed at the same time.

What we ask for

The exact requirements depend on the type of entity and where it is established. Typically we ask for:

• Incorporation or registration documents and the registered address.
• Details and identification of directors, beneficial owners and authorised users.
• A description of the business, its activity and the purpose of the relationship.
• Proof of the bank accounts and wallet addresses the organisation will settle to.
• Where relevant, evidence of the source of funds for particular trades.

Your dealer will confirm the list for your organisation. Documents are held in private, access-controlled storage and are visible only to your organisation and to the desk staff who review them.

Review before release

Every settlement passes through a compliance review stage before funds are released. At that stage the counterparty and the source of funds are confirmed against what was agreed at onboarding. For established relationships the review is usually quick. The stage is shown in the portal so that clients always know where a settlement is and whether anything is needed from them.

Ongoing monitoring

BAJJPAY keeps records of requests, quotes, trades and settlements, and reviews activity against what it knows about each organisation. Organisations are asked to keep their information current, including changes of ownership, directors, authorised users and settlement accounts, and may be asked to refresh documents periodically.

When we decline

BAJJPAY may decline to onboard an organisation, decline a particular request, or delay or decline a settlement where verification cannot be completed, where information provided is inaccurate or incomplete, where the source of funds cannot be established, or where proceeding would breach the law or BAJJPAY's own policies. We are not always able to explain the reason.

Reporting

Where the law requires, BAJJPAY reports suspicious activity to the relevant authorities and cooperates with lawful requests from regulators and law enforcement. In some circumstances the law prohibits us from informing a client that a report has been made.

Contact

Questions about onboarding or compliance can be sent to desk@bajjpay.com. Clients can also raise them with their dealer or through a support ticket in the portal.