AML & KYC policy

BULLISH UK SERVICES LTD (company number 08846965) does not accept anonymous accounts. This policy sets out how we identify our customers, what we monitor, and what we do when something looks wrong. It applies to every account without exception.

1. Purpose

Anonymous financial accounts are useful for moving the proceeds of crime. Identifying our customers and monitoring activity is how we avoid being used that way. It also protects members directly: verification is what allows us to refuse a withdrawal to someone who has compromised a member's email, and what makes account recovery possible.

2. Customer due diligence

Before an account can be funded, we require:

• A verified email address, confirmed by a one-time code.
• A government-issued identity document: a national ID card, driving licence or passport.
• Full name, date of birth, document number and country of issue, taken from that document.
• Confirmation that the holder is at least 16 years old.

Details are read from the document image automatically and presented to you for correction before submission. Every submission is then reviewed by a person. We may request a further document or a clearer image where a submission is unclear, and we may decline an account without being obliged to give a detailed reason.

3. Prohibited and restricted customers

We will not open or maintain an account where:

• The applicant appears on an applicable sanctions list, or is acting for a sanctioned person or entity.
• The applicant is resident in a jurisdiction we are prohibited from serving, or one subject to comprehensive sanctions.
• The identity document is expired, altered, or does not appear to belong to the applicant.
• We cannot establish the identity of the person behind the account to a reasonable standard.
• The account appears to be one of several controlled by the same person. One account per person is permitted.

4. Enhanced due diligence

Additional checks are applied where risk is higher — for example where a customer is a politically exposed person or a close associate of one, where there is a connection to a higher-risk jurisdiction, or where activity does not match the profile we hold. Enhanced due diligence may include questions about source of funds and additional documentation, and approval is escalated internally.

5. Source of funds

We may ask you to explain the origin of funds you deposit, and to provide supporting evidence. This is a routine obligation rather than an accusation. We may decline a deposit, or return it to its origin, where a satisfactory explanation is not provided.

6. Transaction monitoring

Deposits and withdrawals are reviewed, and every balance movement is recorded as a dated ledger entry. Patterns we examine include deposits inconsistent with a member's stated profile, rapid deposit-and-withdrawal cycles that serve no economic purpose, withdrawal addresses associated with known illicit activity, and sets of accounts behaving as one.

7. Suspicious activity reporting

Where we know or suspect that funds are the proceeds of crime, or are intended for terrorist financing, we are required to report it to the appropriate authority. We may be legally prohibited from telling you that such a report has been made, and from explaining why an account has been restricted. Where that is the case, our silence is a legal obligation and should not be read as anything else.

8. Record keeping

Identity documents, verification decisions and transaction records are retained for the period required by law — generally five years following the end of the business relationship — and are then deleted. Documents are stored on a private disk that is not reachable from the public web and are accessible only to authorised reviewers. The privacy policy sets out your rights over this data, and the security page describes the technical controls.

9. Account restriction and closure

We may suspend or close an account, and withhold a withdrawal, where verification cannot be completed, where we are required to do so by law or by a competent authority, or where we reasonably suspect fraud, money laundering or a breach of our terms of service. Where we are permitted to explain the reason, we will.

10. Regulatory status

BULLISH UK SERVICES LTD is a company registered in England and Wales. It is not authorised or regulated by the Financial Conduct Authority, and the services described on this site are not covered by the Financial Services Compensation Scheme or the Financial Ombudsman Service. This policy describes our own procedures; it is not a statement of regulatory authorisation.

11. Contact

Questions about this policy, or about a verification decision, can be sent to support@bullish.jo3.org.