Anti-Money Laundering Policy

Last Update: Mar 29, 2019

This is the anti-money laundering and terrorist financing policy (the “Policy”) of Clearflow PTE. Ltd, a company registered in Singapore under UEN number: 201842687D, and the following address: 24 RAFFLES PLACE #27-01 CLIFFORD CENTRE SINGAPORE (“We”, “we”, “our”, or “us”). We are the owners and operators of (the “Platform”), and this Policy applies to your use of the Platform.

Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities. This is achieved by the placement of the money launderer’s cash into the financial system, by creating complex layers of financial transactions to disguise the origin of the assets and by integration of the laundered proceeds into the economy as clean money.

Money laundering (“ML”) is often thought of as applying to the proceeds of drugs related crime; however, terrorism and other criminal activities, are equally relevant.

We take ML and counter terrorism financing (“CTF”) seriously, and apply this Policy rigorously to our business to protect against such illicit activities.

Use of in a manner that breaches ML or CTF rules, or that otherwise is connected to criminal property is strictly forbidden and could be a criminal offence.

Our AML and CTF procedures are made up of activities that we are physically able to implement  (our “ML procedures”), in the light of our vision of providing a 1st class service without retaining your personal information and therefore securing it against theft and abuse, and ensuring our compliance with global data protection laws, including the EU General Data Protection Regulation (aka GDPR) – please refer to our data privacy policy ( for further information on our position relating to privacy.

We strive to continuously review and improve our ML procedures, which are therefore updated regularly. You will be notified with a notice on the Platform every time such an update occurs.

Our current ML procedures are as follows:

  1. Any suspicions or knowledge of money laundering will be reported to our Compliance Officer who is contactable at (“Compliance Officer”). As use of the Platform does not involve our obtainment of any of your personal information other than the outgoing public key (the receiving Bitcoin address), the public key is therefore the only information we use together with data points associated with such public key.

  1. A detailed record of all internally reported suspicions will be maintained. Until the Compliance Officer advises the worker making the internal report that no report to any authorities is to be made, any further transactions or activity in respect of that customer will be reported to the Compliance Officer as they arise.

  1. If the Compliance Officer concludes that the internal report does give rise to knowledge or suspicion of money laundering or terrorist financing, he/she will make a report to the relevant authorities, as required under applicable laws.

  1. The United Nations, European Union, United States, United Kingdom (and other governments) are each able to designate persons and entities as being subject to financial sanctions. Such sanctions normally include a comprehensive freeze of funds and economic resources, together with a prohibition on making funds available to the designated target. A consolidated list of all targets to whom financial sanctions apply is maintained by various authorities and can include Bitcoin addresses (and may include other crypto addresses in the future). The Compliance Officer will ensure that we monitor relevant sanctions lists for relevant Bitcoin and other addresses.

  1. We take appropriate measures so that all relevant persons within the business are made aware of the law relating to money laundering and terrorist financing and are regularly given training in how to recognise and deal with transactions and other activities which may be related to money laundering or terrorist financing.

  1. At least annually, the Compliance Officer will produce a report for our governing body and senior management on the operation and effectiveness of our data privacy and ML/CTF systems and controls to enable us to identify, assess, monitor and manage the risk that we may be used to further money laundering, data security violations or breaches of the laws relating to ML/CTF and/or data privacy. With respect to ML and CTF, the report should:

  1. bring to the attention of senior management areas where the operation of controls in respect of ML and CTF should be improved, and proposals for making appropriate improvements. The progress of any significant remedial programmes will also be reported to senior management; and

  1. report on the outcome of any relevant quality assurance or internal audit reviews of our AML/CFT processes, as well as the outcome of any review of our data privacy risk assessment procedures (see our Data Privacy Policy for further information).

  1. Our senior management must take necessary action to remedy deficiencies and asymmetries identified by any report.

Please do not hesitate to contact our Compliance Officer at: should you have any questions relating to this Policy.