AML/CFT Compliance Summary for BlockDev PLC

At BlockDev PLC, a company registered under the laws of Bulgaria (registry number 208043482) with its registered address at 9A, Positano Str., Sofia 1000, Bulgaria, we are fully committed to adhering to stringent Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations. Our business activities, which include providing services as an on and off-ramp provider for open banking and cryptocurrency transactions, are conducted in full compliance with EU regulations, including the Bulgarian Law on Measures Against Money Laundering (LMML).

Our goal is to ensure the integrity and security of our services, protect our clients from financial crimes, and maintain a safe and lawful environment for all users and business partners.

Why We Collect Your Information

In line with EU AML/CFT obligations, we collect specific information from our clients—whether individual users or corporate partners—to conduct thorough due diligence. This process is designed to:

  • Verify the identities of individuals and legal entities.
  • Ensure transparency in all transactions.
  • Prevent our services from being used for illicit activities such as money laundering, terrorism financing, or any form of illegal financial transactions.

By collecting and verifying your data, we are better equipped to:

  • Protect our clients’ assets.
  • Comply with the applicable AML/CFT laws.
  • Safeguard the financial system from misuse.

What Information Do We Collect?

Depending on whether you are an individual user or a corporate partner, we may collect the following information as part of our onboarding and transaction monitoring process:

For Individual Users:

  • Full name, date of birth, and place of birth.
  • Official identification number (e.g., passport, national ID, or residence card).
  • Current nationality and any additional citizenships.
  • Residential address (including proof of address such as utility bills, bank statements not older than 6 months, etc.).
  • Source of funds/ wealth (especially in cases involving large or unusual transactions).
  • Status as a Politically Exposed Person (PEP), or relationships with a PEP.

For Corporate Partners:

  • Full company name, legal form, registration number, and headquarters address.
  • Identification of company directors, beneficial owners, and legal representatives.
  • Ultimate Beneficial Owners (UBOs) — individuals who ultimately control the business( rights equal or more than 25 %).
  • Business activity, the scope of operations, and expected transaction volumes.
  • Relevant licenses, certifications, or registrations.

How We Verify Your Information

To ensure the accuracy and reliability of the information you provide, BlockDev PLC performs rigorous verification procedures, which may include:

  • Document verification: We check documents such as identification, proof of address, and corporate certificates.
  • Cross-referencing registries: We confirm company details with public databases and commercial registries to verify legitimacy.
  • Screening: Screening helps BlockDev PLC identify and mitigate risks associated with money laundering, fraud, or terrorism financing. By evaluating a client’s background and financial activities, we assess their risk profile. If a client is associated with sanctioned countries, is listed as a sanctioned individual or entity, holds the status of a Politically Exposed Person (PEP), or exhibits suspicious activity identified through adverse media reports, BlockDev PLC will take appropriate actions. These may include implementing Enhanced Due Diligence (EDD) procedures to further assess the risks or, in certain cases, refusing to onboard the client entirely. 
  • Enhanced Due Diligence (EDD): We apply additional scrutiny when there are higher risks (e.g., high transaction volumes, clients in high-risk jurisdictions, or politically exposed persons). This may include obtaining financial statements, legal agreements, and more detailed information about the source of funds.

When We Apply Enhanced Due Diligence (EDD)

EDD is employed in cases where the risk of money laundering or terrorism financing is higher. The circumstances under which EDD may be triggered include:

  • Clients operating in high-risk sectors (e.g., crypto-assets, cash-intensive industries).
  • Clients based in or associated with high-risk jurisdictions, as identified by international bodies.
  • Clients who are Politically Exposed Persons (PEPs) or have close associations with PEPs.
  • Unusual or complex transactions lacking a clear economic or lawful purpose.

In these instances, BlockDev PLC may request additional documentation to ensure full transparency and compliance.

Who We Will Not Onboard

In accordance with EU and Bulgarian AML/CFT regulations, BlockDev PLC reserves the right to refuse onboarding or to terminate services with clients in the following situations:

  • Inability to verify identity: If we cannot verify the identity of the client, beneficial owner, or key personnel.
  • Involvement in high-risk activities: Clients associated with activities deemed high-risk for money laundering or terrorism financing.
  • Politically Exposed Persons (PEPs): Although PEPs can be onboarded, they will undergo Enhanced Due Diligence. If risks are deemed unacceptable, we may refuse to onboard.
  • Suspicious activities: Clients engaged in illegal activities (e.g., fraud, tax evasion, terrorism financing).
  • Listed on sanctions lists: Clients on official sanctions lists (e.g., EU, UN, or US sanctions).
  • Conflicting beneficial ownership: If there are discrepancies regarding the Ultimate Beneficial Owner (UBO) or if the information provided does not align with public records (e.g., Bulgarian Commercial Register).

Why We Need This Process

The onboarding, monitoring, and due diligence processes are not just legal requirements but are crucial for ensuring the safety and security of our business. By collecting and verifying client information, we can:

  • Protect your interests by preventing fraud, money laundering, and terrorism financing.
  • Ensure compliance with both local and international regulations.
  • Maintain a secure environment that benefits all legitimate clients and partners.

This process allows us to provide high levels of transparency and security while adhering to both EU and Bulgarian legal standards. BlockDev PLC is committed to safeguarding your financial dealings and contributing to a safer crypto-asset ecosystem.

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