KYC - AML Policy

Policy Statement

Even though Satoshi Counter is not a Money Service Business, Satoshi Counter owners and directors are completely dedicated to identifying, addressing and mitigating any risk of money laundering, terrorism financing or other criminal activities.

In order to do so, Satoshi Counter establishes voluntarily the present compliance regime and in doing so establishes client identification and record keeping policies and procedures using the guidelines elaborated by the Financial Transactions and Reports Analysis Center of Canada (Fintrac) in regards to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

The objective of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act is to help detect and deter money laundering and the financing of terrorist activities. It is also to facilitate investigations and prosecutions of money laundering and terrorist activity financing offences.

Statement on Money Laundering

Satoshi Counter owners, officers, directors and staff will operate with full knowledge of the nature and scope of money laundering and its negative effects on society, and we define money laundering as follows:

“Money laundering is the process used to disguise the source of money or assets derived from criminal activity. Profit-motivated crimes span a variety of illegal activities from drug trafficking and smuggling to fraud, extortion and corruption.”

They acknowledge that the most common techniques of laundering money are:

Placement: involves placing the proceeds of crime in the financial system;

Layering: involves converting the proceeds of crime into another form and creating complex layers of financial transactions to disguise the audit trail and the source and ownership of funds (e.g., the buying and selling of stocks, commodities or property)

Integration: involves placing the laundered proceeds back in the economy under a veil of legitimacy.

Statement on Terrorist Financing

Satoshi Counter owners, officers, directors and staff will operate with the utmost concern to ensure that none of its clients are involved terrorist financing.

Terrorist financing provides funds for terrorist activity. It may involve funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion.


Satoshi Counter’s membership system is based on the level of identification and information provided by the members. The more information the members provide, the higher their membership level. A higher membership level entitles users to higher transaction limits and access to additional payment methods.

The following methods are used to identify our members:

Identification documents

Members upload identification documents. The validity of these documents may be assessed by Satoshi Counter or third party service providers.

Telephone number

Members are identified by submitting a valid phone number. The validity of the phone number may be assessed by sending a unique SMS code to the member’s telephone number, or calling the member directly.

Identification and membership thresholds

Level 1: information required

  • Full name
  • Email address
  • Telephone number

Maximum legal transaction limit: $3000 per 24h period

Level 2: information required

  • Government-issued ID
  • Physical address
  • Occupation

Maximum legal transaction limit: $10000 per 24h period

Level 3: information required

  • Bank reference
  • Utility bill with proof of address
  • Documentation providing credible explanation for source of funds (on judgement of Satoshi Counter’s compliance officer)

Maximum legal transaction limit: ∞

Record keeping

As every other legitimate Bitcoin exchange and retail company, Satoshi Counter keeps a detailed log of every transaciton it conducts with its members. This is required by law, but it also helps us to maintain a loyalty program and provide customer service.