AML/KYC Policy

This Anti-Money Laundering and Know Your Customer Policy (the "AML/KYC Policy") is established to prevent and mitigate possible risks of being involved in illegal or illicit activities.

This policy is subject to changes and updates from time to time to ensure compliance with any applicable legislation and global AML/KYC practices.

«Beneficial Owner» means any natural person or persons who ultimately own or control the User and, or the natural person or persons on whose behalf a transaction or activity is being conducted.

«High Risk Jurisdiction» means the jurisdictions designated as a high risk jurisdiction in respect of any service from time to time.

«Politically Exposed Person» means a natural person who is or has been entrusted with prominent public functions, other than middle ranking or more junior officials.

«Sanctioned Person» means any individual or entity identified on a sanctions list issued by relevant authorities.

We will screen users prior to enabling any transaction and will continue to screen such users on an ongoing basis to ensure compliance with applicable regulations.

This screening ensures that users are not sanctioned persons, from sanctioned jurisdictions, or from prohibited jurisdictions.

We adopt a risk-based approach to combating money laundering and terrorist financing. This ensures that measures are commensurate to the identified risks.

Prior to providing services, we will:

• Identify and verify user identity based on reliable documentation
• Identify beneficial owners where applicable
• Obtain information on the purpose and nature of the business relationship
• Verify authority for those acting on behalf of users

We continuously monitor business relationships with users on a risk-sensitive basis through:

• Regular review of user information and documentation
• Transaction monitoring and analysis
• Enhanced due diligence where required
• Regular risk assessments

We maintain updated lists of sanctioned, prohibited, and high-risk jurisdictions based on guidance from relevant regulatory authorities.

Enhanced due diligence measures apply to users from high-risk jurisdictions, while services may be restricted or prohibited for users from sanctioned or prohibited jurisdictions.

Certain situations require enhanced due diligence measures, including:

• Users from high-risk jurisdictions
• Politically exposed persons and their associates
• Unusual transaction patterns
• Complex corporate structures
• Non-face-to-face business relationships

We maintain comprehensive records of all user identification data, transaction records, and supporting documentation for the period required by applicable law.

All records are kept in a form that allows for timely retrieval and provision to relevant authorities when required.

A designated Money Laundering Reporting Officer (MLRO) is responsible for:

• Overseeing AML/KYC compliance
• Investigating suspicious activities
• Filing suspicious activity reports
• Training staff on AML/KYC procedures
• Maintaining relationships with regulatory authorities

We are committed to reporting suspicious activities to relevant authorities in accordance with applicable laws and regulations.