Anti-Money Laundering Program

The company's policy is to prohibit and actively prevent money laundering and all activities that facilitate money laundering or the financing of terrorist or criminal activities by complying with all applicable requirements of the EU as well as the US regulations and its implementing provisions.

Money laundering generally refers to activities aimed at concealing or disguising the true origin of criminal proceeds so that they appear to come from legitimate sources or represent legitimate assets.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable EU regulations, EU laws and EBA rules. They are regularly reviewed and updated to ensure that appropriate policies, procedures and internal controls are in place.

The company has appointed an AML Compliance Officer, who has full responsibility for the company's AML program with practical knowledge of anti-money laundering and its implementing regulations.

The AML Compliance Officer ensures that the company keeps and maintains all required AML records and ensures that reports of suspicious activities are made when required and submitted to the relevant authorities.

We will respond to authorities requests regarding user accounts and transactions by promptly searching our records to determine whether we maintain or have maintained a user account for, or have conducted transactions with, any named individual, entity, or organization.

We will not disclose the fact that an authority has requested or received information from us in response to a request, except to the extent necessary to fulfill the request for information.

We implement a comprehensive Customer Identification Program that includes:

Before concluding a contract and on an ongoing basis, we check whether a customer is not on the sanctions list or carries out transactions that are prohibited by economic sanctions and embargo programs.

We monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business.

We will investigate any patterns of unusual activity and, where appropriate, report suspicious activities to the relevant authorities.

We maintain all required AML records and protocol or form submissions for at least five years. This includes customer identification information, transaction records, and suspicious activity reports.

We provide ongoing AML training for our employees and freelancers to ensure they understand their obligations under our AML program and can identify and respond appropriately to suspicious activities.

We conduct independent testing of our AML compliance program to ensure its effectiveness and identify areas for improvement.

We maintain confidential channels for reporting potential AML violations and ensure that all reports are investigated promptly and thoroughly.