is committed to comply with all relevant AML and funding of terrorism regulations and the following policy has been derived from the general principles, laws, regulations and directives for combating money laundering.

We believe that compliance with AML and CFT regulations is essential for the integrity of financial systems and prevention of our company from being used, intentionally or unintentionally, by criminal elements.

We have put in place Know-Your-Customer (KYC) programs as an essential element for service, risk management and control procedures. We are obliged not only to establish the identity of its clients, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that client or type of account. The program also includes record keeping requirements, the reporting of suspicious activity and AML training.

// What is Money Laundering?

Money laundering includes all forms of handling or possessing criminal property, including possessing the proceeds of one's own crime, and facilitating any handling or transfer of criminal property for another person; including the proceeds derived from any act of fraud, bribery or corruption. Where criminal property includes money or money's worth, securities, tangible and intangible property; including the receipt, handling and transfer of funds derived from criminality.

A simplified view of an effective money laundering operation involves three stages:

Placement of physical cash (e.g. in a bank account). A simplified view of an effective money laundering operation involves three stages:

Layering. By using funds from the bank account and undertaking multiple transactions which confuse the audit trail and separate the money from its origin

Integration of laundered proceeds into the legitimate economy, so that it appears to be legitimate by being presented as normal business funds.

For the purpose of this policy, money laundering also includes activities relating to terrorist financing, including handling or possessing funds to be used for terrorist purposes as well as proceeds from terrorism.

When dealing with customers, we are alert to the possibility that customers, their counterparties or others (with or without the customer’s knowing participation) may try to launder money using our services – by way of layering or integration.

// Know-Your-Customer

We ask clients a number of questions during the application stage in order to understand clients and ensure that the applicant is not a victim of financial crime. Documentation is collected from clients in order to verify the information provided at the application stage. Such documents may be verified electronically during the application process.

Periodically, we also request clients to provide updates to the personal information which has been provided at the application stage to ensure that the data and information about its clients is up to date.

// Customer Acceptance

We maintain clear customer acceptance policies and procedures, including a description of the types of client that are likely to pose a higher than average risk. Before accepting a potential client, KYC and due diligence procedures are followed, by examining factors such as customer's background, country of origin, public or high profile position, linked accounts, business activities or other risk indicators.

Extensive due diligence is essential for an individual with high net worth but whose source of funds is unclear. New clients' money is transferred through a reputable bank. Banks have their own anti-money-laundering procedures. A decision to enter into business relationships with higher risk customers, such as politically exposed persons, is taken exclusively at senior management level.

// Controls

We have a number of internal controls including but not limited to the non-acceptance of cash and the non-acceptance of third party deposits and redemptions. We will not accept as customers, persons or entities from restricted or sanctioned countries, organizations. Reference points for such reviews include the websites of:
- Australian Department of Foreign Affairs and Trade,
- Nations Consolidated Lists,
- US Office of Foreign Assets Control,
- FATF.

We do not accept US Citizens.

We do not accept any anonymous accounts and do not maintain any relationships with shell banks.

// Customer Identification

We obtain all information necessary to establish to our full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship. The extent and nature of the information depends on the type of applicant (personal, corporate, etc.) and the expected size of the account.

Customer identification is an essential element of KYC standards. For the purposes of this policy, a customer includes:
- The person or entity that maintains an account or those on whose behalf an account is maintained (i.e. beneficial owners);
- The beneficiaries of transactions conducted by professional intermediaries;
- Any person or entity connected with a financial transaction who can pose a significant reputational or other risk to our company.

Client identification must be carried out as soon as reasonably practicable after first contact is made. We maintain a systematic procedure for identifying new customers and cannot enter into a service relationship until the identity of a new customer is satisfactorily verified.

We pay special attention in the case of non-resident customers and in no case are short-circuit identity procedures followed just because the new customer is unable to present enough documents and information to satisfy the KYC and due diligence procedures.

As part of its obligation to exercise due diligence in customer identification, we must confirm that the identity information which it holds for its customers remains fully updated with all necessary identification and information throughout the business relationship. We regularly review and monitor on a regular basis the validity and adequacy of customer identification information in its possession.

Where the customer refuses or fails to provide us with the required documents and information for identification, before entering into the business relationship, or during the execution of an individual transaction without adequate justification, we will not proceed in a contractual relationship or will not execute the transaction and may also report it to the AML/CFT Supervisor. This can lead to a suspicion that the customer is engaged in money laundering and terrorist financing.

// Required Customer Information and Verifying Information

The following information will be collected for new clients:
- True full name and/or names used;
- Current permanent address, including postal code;
- Date of birth;
- Profession or occupation.

Names should be verified by reference obtained from a reputable source which bears a photograph, such as:
- Current valid full passport;
- Government issued photo identification card.

We shall not attempt to determine whether the document that the customer has provided for identification has been validly issued. For verification purposes, we shall rely on government-issued identification to establish a customer’s identity. We, however, will analyze the information provided to determine if there are any logical inconsistencies in the information obtained.

In addition to the customer’s name verification, the current permanent address will be verified by obtaining any one of the following documents in original form:
- Copy of a recent utility bill;
- Local tax authority bill;
- Bank statement;
- Credit card monthly statement.

The following information will be collected for Corporate Clients:
- The original or certified copy of the Certificate of incorporation;
- Constitution, Memorandum and articles of association;
- Resolution of the Board of Directors to enter into transactions on the Cryptocurrency market and conferring authority to those who will act for the customer;
- Directors and Shareholders registers;
- Identity of individuals who are connected with the Company;
- The Company's business profile in terms of nature and scale of activities;

Company searches, and other commercial enquiries to ensure that the applicant has not been or in the process of being dissolved, struck off, wound up or terminated. If changes to Company structure occur or ownership occurs subsequent to opening of an account with the Company, further checks will be made.

Identity verification for Corporate Clients aims to identify:
- The Company;
- The Directors;
- All persons duly authorized to operate the account;
- Ownership structure;
- In case of private companies, the major beneficial shareholders;
- Latest audited financial statements (if available).

We must verify the identity of beneficial owners of accounts. For legal persons, we require such data and information to understand the ownership and control structure of the customer. Regardless of the customer’s type (e.g. natural or legal person, partnership or sole trader), we take adequate data and information on the customer's business activities and the expected pattern and level of transactions.

The identity of all customers is verified on the basis of reliable data and information given or received from independent and reliable sources, i.e. those data and information that is difficult to be falsified or to be obtained in an illegal way.

// Performance by third parties

We may rely on third parties for applying the requirements in respect of customer's identification procedures and customer due diligence measures provided that all data and information is held by the third person for customer identification, and certified copies of the originals are provided to us.

// On-Going Monitoring and Recording of Accounts and Transactions

On-going monitoring is an essential aspect of effective KYC procedures. We can only effectively control and reduce the risk if we have an understanding of normal and reasonable account activity of our customers so that we have means of identifying transactions which fall outside the regular pattern of an account's activity. Without such knowledge, it is likely to fail in its duty to report suspicious transactions to the appropriate authorities in cases where they are required to do so. The extent of the monitoring needs to be risk-sensitive.

For all accounts, we have systems in place to detect unusual or suspicious patterns of activity. This is done by establishing limits for a particular class or category of accounts. Particular attention is paid to transactions that exceed these limits.

Certain types of transactions alert to the possibility that the customer is conducting unusual or suspicious activities. They may include transactions that do not appear to make economic or commercial sense (big transactions), or that involve large amounts of cash deposits that are not consistent with the normal and expected transactions of the customer.

Intensified monitoring for higher risk accounts is conducted. We have set key indicators for such accounts, taking note of the background of the customer, such as the country of origin and source of funds, the type of transactions involved, and other risk factors.

// Reporting Suspicious Activity

In line with the relevant regulations any suspicious activity of money laundering and funding of terrorism is reported to the relevant authorities, after investigation.

Examples of suspicious activity include but not limited to:
- Out-of-the-ordinary account activity. The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer's stated business strategy.

- Out of expected range of transaction volumes or financial thresholds.
- The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
- Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
- The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
- The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
- The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.

// Record Keeping

Information provided by our customers is retained for a period of five years and protected using the latest technology. The 5 year period is calculated following the carrying out of the transactions or the end of the business relationship.

More specifically, we obtain customer identification papers and retain copies of them for at least five years after an account is closed. We also retain all financial transaction records for at least five years from the date when our relationship with the client was terminated or a transaction was completed.

Customer information received by us is treated confidentially in accordance with applicable law.

The following records are kept:
- Copies of the evidential material of the customer identity;
- Relevant evidential material and details of all business relations and transactions, including documents for recording transactions in the accounting books;
- Relevant documents of correspondence with the customers and other persons with whom they keep a business relation.

All documents and information are available rapidly and without delay to the authorities for the purpose of discharging the duties imposed on them by the law.

Documents and information must be original or certified true copies.

// Training of employees

We conduct extensive due diligence on our employees before recruitment. In addition, our employees are provided with regular training so that the employees are adequately trained in KYC procedures and in order for employees to be aware of possible patterns and techniques in money laundering and to detect possible suspicious activity.

The timing and content of training for various employee categories is adapted by our company for our own needs. Training requirements have a different focus for new employees, front-line employees, compliance employees or employees dealing with new customers.

New employees are educated in the importance of KYC policies and the basic requirements. Employees who deal directly with the customers are trained to verify the identity of new customers, to exercise due diligence in handling accounts of existing customers on an on-going basis and to detect patterns of suspicious activity.

Regular refresher training is provided to ensure that employees are reminded of their responsibilities and are kept informed of new developments.

// Regular Audits and Reviews

Regular Audits are carried out by reputable audit firms in order to ensure that the policies and procedures are being complied with. Our policies and procedures are regularly reviewed to ascertain that these reflect the current regulations and external environment.

Should you have any questions or queries regarding the contents of this policy please do not hesitate to contact us at your convenience using the details in the Contacts section of this site.

// Additional Information Notice

Regulations require that we keep all customer information up-to-date by continuously monitoring our business relationships. That is why we might need to ask our customers to provide us with additional documents and information if required.

If at any later stage, changes occur in the structure of the ownership status or to any details, the client should inform us and provide any new/updated information and documents.

If in the country of the potential/existing client any of the required document does not exist in the form required by us, the compliance officer may accept a similar document serving the needs of due diligence.