BCB Group Risk Appetite Statement


This Statement defines the BCB’s risk appetite, risk tolerance and strategy in the face of money-laundering, terrorist financing, sanctions and other related financial crimes risks.

The principles outlined in this statement apply to our direct B2C and B2B clients and indirectly to our ‘nested customers’ in turn on boarded by our clients.

Overview of Risk Appetite

BCB maintains a comprehensive ML/TF/Sanctions management framework, which emphasises the importance of regulatory standards, professionalism, maintaining high quality staff, and accountability to stakeholders. BCB’s risk appetite underpins both this framework and the firm’s ML/TF mitigation strategy.

Financial Crime Risk Appetite Statement

BCB has a low-risk tolerance for financial crime risk. To this end BCB has put in place the following mitigants and controls to prevent and detect BCB being used to facilitate financial crime:

  • Financial Crime Business Wide Risk Assessment;
  • Financial Crime Policies and Procedures;
  • Client Due Diligence (CDD) procedures (including initial and ongoing screening);
  • Transaction Monitoring (TM);
  • AML/counter-terrorist financing (CTF) training for the Board and all employees.

BCB Group is committed to combating financial crime and continually strives to ensure that accounts held at our Firm are not misused for the purpose of ML/TF irrespective of product or origination. Our financial crime risk management controls are proportionate to the risks we face. In line with this. BCB will not:

  • Knowingly facilitate criminal activities by clients, including but not limited to tax evasion, ML, TF or any other fraudulent or illegal activity.
  • Accept any deliberate or systemic breaches of applicable laws and regulation.
  • Facilitate transactions with entities or individuals that;
    • Cannot be identified in accordance with BCB’s KYB/KYC program and are unresponsive to information requested by BCB which is significant to their identification; or Intentionally provide misleading information to BCB which is significant to their identification or activities;
    • are sanctioned or known to be associated with the financing of terrorism;
    • are known and verified to be operating without required licensing and/or registration
  • Operate any line of business or do business with any client segment in which the Board believes that its control environment cannot protect the Firm from risks that exceed its stated tolerance.

In addition, any high-risk clients (as determined by our client risk assessment methodology) must be approved by the MLRO prior to onboarding and subject to periodic reviews on an ongoing basis (existing clients). High-risk clients that do not receive approval from the MLRO must be either not onboarded, or offboarded immediately (existing clients) in accordance with the offboarding procedures.

High Risk Jurisdictions

In all instances BCB seeks to determine the provenance of all parties it enters into relationships with prior to commencement of the relationship. Where it is determined that i) a potential client, business partner or supplier is established or otherwise has a presence or ii)wishes to execute a transaction(s) with another party in a ‘high-risk’ third country BCB will in all instances conduct EDD.

Being “established in” a high-risk country means:

  • Corporates – being incorporated in or having its principal place of business in that country, or, in the case of a financial institution or credit institution, having its principal regulatory authority in that country
  • Individuals – being resident in that country, but not merely having been born in that country

High-risk countries are those with significant deficiencies in their money laundering countermeasures, and/or a significant level of systemic corruption.

BCB use multiple sources to identify and track those countries it deems ‘high risk’, taking specific reference to:

  • Financial Action Task Force ( FATF) recommendations e.g Blacklist and Greylist)
  • EU Commission recommendation
  • OFAC
  • UK Money Laundering and Terrorist Financing Regulations
  • EU list of non-cooperative jurisdictions

BCB will also reference other sources when assessing country risk including Basel AML Index and the Corruption Perception Index.

Any matter with high-risk third country involvement must be reported to the MLRO immediately who will decide whether the client will be onboarded and if so, what additional EDD measures should be adopted.

The list set out below reflects those countries BCB treat as high risk for determining whether a given relationship will be prohibited or whether EDD is required prior to onboarding or facilitating transactions. Further additions or amendments to the list may arise depending on the risk appetite of our business partners.

BCB maintains a programme of ongoing monitoring to ensure the following list is maintained, changes to the list are made on an adhoc and monthly basis.

Prohibited Jurisdictions *

Country Rationale for Restriction (FATF, EU Prohibition, UK Prohibition, US Prohibition, BCB Risk Appetite)
Belarus US, UK Sanctions
Burundi UK Sanctions
Democratic People’s Republic of Korea (North korea) FATF Blacklist
Democratic Republic of the Congo FATF Greylist, UN Sanctions
Iran FATF Blacklist
Iraq UK Sanctions, BCB Risk Appetite
Lebanon UN, UK Sanctions
Libya UN, UK Sanctions
Mali UN, UK Sanctions
Myanmar FATF Blacklist, EU, UK
Russia US, UK Sanctions
The Central African Republic UK Sanctions, BCB Risk Appetite

High Risk Jurisdictions

Country Rationale for Restriction (FATF, EU Prohibition, UK Prohibition, US Prohibition, BCB Risk Appetite)
Albania FATF Greylist, UK
Afghanistan EU, UK Sanctions
American Samoa EU non coop
Anguilla EU non coop
Bahamas EU non coop
Bahrain BCB Risk Appetite
Barbados FATF Greylist, EU, UK
Bermuda BCB Risk Appetite
Bolivia BCB Risk Appetite
Bosnia and Herzegovina UK Sanctions
British Virgin Islands BCB Risk Appetite
Burinka Faso FATF Greylist, EU, UK
Cambodia FATF Greylist, EU, UK
Cameroon BCB Risk Appetite
Cayman Islands FATF Greylist, EU, UK
China BCB Risk Appetite
Colombia BCB Risk Appetite
Cuba US Sanctions
Egypt BCB Risk Appetite
Fiji EU Non Cooperative
Gibraltar UK, BCB Risk Appetite
Guam EU Non Cooperative
Guernsey BCB Risk Appetite
Guinea UK Sanctions
Guinea-Bissau UN Sanctions, UK Sanctions
Haiti FATF Greylist, EU, UK
Isle of Man BCB Risk Appetite
Jamaica FATF Greylist, EU, UK
Jersey BCB Risk Appetite
Jordan FATF Greylist, EU, UK
Liechtenstein BCB Risk Appetite
Macau BCB Risk Appetite
Madagascar BCB Risk Appetite
Mali FATF Greylist, EU, UK
Mexico BCB Risk Appetite
Monaco BCB Risk Appetite
Morocco FATF Greylist, EU, UK
Mozambique FATF Greylist, UK
Nicaragua EU, UK Sanctions
Nigeria BCB Risk Appetite
Pakistan EU, BCB Risk Appetite
Palau EU Non Cooperative
Panama FATF Greylist, EU, UK, EU non coop
Rwanda BCB Risk Appetite
Samoa EU Non Cooperative
Senegal FATF Greylist, EU, UK
Somalia UN, UK Sanctions
South Sudan FATF Greylist, EU, UK
Sudan BCB Risk Appetite
Syria FATF Greylist, EU, UK, US
Tanzania FATF Greylist, UK
The Philippines FATF Greylist, EU, UK
Trinidad and Tobago EU Restriction, EU non coop
Turkey FATF Greylist, UK
Turks and Caicos Islands EU Non Cooperative
Uganda FATF Greylist, EU, UK
Ukraine BCB Risk Appetite
United Arab Emirates FATF Greylist,, UK
US Virgin Islands EU Non Cooperative
Vanuatu EU Restrictions, EU non coop
Venezuela US, UK Sanctions
Vietnam BCB Risk Appetite
Yemen FATF Greylist, EU, UK, Sanctions
Zimbabwe EU Restriction

Prohibited Client Business Activities

Whilst BCB’s client base is focused on those entities active within the digital asset and crypto currency space we recognise that our clients may have use cases which involve them being active in other sectors. BCB also recognises that some industries carry a greater inherent ML/TF risk than others. As such BCB applies further restrictions and prohibitions depending on the industry in which clients operate.

BCB will not enter into business relationships with entities or individuals actively involved in or with strong connections to the following sectors;

  • Adult industry
  • Gambling
  • Arms/weapon dealing
  • Illegal drugs and substances designed to mimic illegal drugs
  • Counterfeit goods
  • Conducting a business without the correct licences/jurisdictional approvals in place
  • Multi level marketing/pyramid schemes

BCB will apply enhanced due diligence to any clients actively involved in or with strong connections to the following sectors:

  • Mining and extraction of gold, precious metals and gemstones
  • Luxury goods
  • Pharmaceuticals
  • Crypto Lending businesses
  • Spread betting companies

All the restrictions above are communicated to BCB business partners at the inception of the relationship and on an ongoing basis in line with any further amendments/additions to these lists.

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