RISK MANAGEMENT POLICY

CUSTOMER, MONEY LAUNDERING AND FINANCING OF TERRORISM, SANCTIONS AND COUNTRIES (AML/CTF & KYC & SANCTIONS & COUNTRY)

The purpose of the Client Risk Management Policy, Money Laundering and Terrorist Financing, Sanctions and Countries (AML/CTF & KYC & SANCTIONS & COUNTRY POLICY, hereinafter referred to as "Policy" or "AML/KYC Policy") is to establish a system of controls and mechanisms to prevent the inclusion "Site" service and/or "Site" services/services to money laundering and/or terrorist financing and/or violation of established sanctions restrictions, preservation and maintenance of "Site" reputation during interaction with customers, counterparties and representatives of authorized bodies.

This Policy describes the basic standards, principles, rules and approaches used by the "Site" to study its customers and counterparties, conduct activities to manage the risks of money laundering and financing of terrorism, sanctions and countries.

Internal documents on AML/CTF risk management and KYC/CDD procedures are additionally developed by the Company and are internal documents of the Company with limited access. Such documents comply with this Policy.

The Company ensures compliance with the requirements of this Policy and current legislation by all Company employees. According to the Policy, the words "Site", "Company", "service", "Site service", "we", "us" or "our" refer to the company "Site", including but not limited to its owners, directors, investors, and other related persons.Depending on the context, the "Site" may also apply to the services, products, content or other materials provided by the "Site". Accepting Terms of Use, you automatically agree to this Policy.

All capitalized terms used in this AML/KYC Policy and not otherwise defined have the same meanings as in the Terms of Use.

Definitions Capitalized terms in this Policy have the following meanings:

"Site" - the site "Site" and/or the company and/or service that provides the service/services on the site "Site".

Prohibited Conduct - means any illegal conduct, which includes fraud, corruption, money laundering, conspiracy, terrorist financing and any other criminal conduct.

Fraud - means the use of deception for the purpose of pursuing personal interests and harming the interests of Users and/or "Site".

Scam / Fraud — a method of deception, fraud to obtain money from Internet users, may include hiding information or providing false information in order to extort money from victims.

Corruption means offering, providing, receiving or lobbying, directly or indirectly, for anything of value that can influence the actions of another party.

Money laundering - means a scheme of financial transactions, the purpose of which is to hide the identity, source and destination of illegally obtained money or the financing of illegal activities.

Anti Money laundering (AML) is a set of measures and procedures aimed at detecting and/or preventing the use by the company/site "Site" and/or the services provided by the "Site" for money laundering.

Counter-terrorist financing / Counter-terrorist financing (CTF) - a set of measures and procedures aimed at detecting and/or preventing the use by the company/site "Site" and/or services provided by the "Site" for financing terrorism.

Sanctions - Economic sanctions are commercial and financial sanctions applied by one or more countries against targeted self-governing states, groups or individuals.

Red flags are a warning or indicator that indicates the presence of a potential problem or threat with the Customer's operation that passes through the Company and/or the Company's Service.

Collusion - means an agreement between two or more parties aimed at achieving an improper goal, including undue influence on the actions of another party.

Terrorist financing means the provision or collection of funds by any means, directly or indirectly, with the intention of using them or under the condition that they will be used in whole or in part to commit any crime related to terrorism.

Criminal conduct - means a crime in any part of the world or something that would qualify as a crime in any part of the world if it were to occur there.

Know Your Client (KYC) is a set of measures and procedures aimed at obtaining information about the client and its activities for the purpose of managing the company's risks.

Customer Due Diligence (CDD) is a check of data/information about the client and other checks related to the study of the client and its activities for the purpose of a comprehensive assessment of the client's risk in its service and during its service.

Politically exposed person (PEO) means a natural person who plays an outstanding public role within a certain country or at the international level.

Regulatory Requirements - means any applicable law, statute, regulation, order, judgment, decision, recommendation, rule, policy (including but not limited to KYC/AML/CTF policy) or guidance adopted or issued by Parliament , government or any competent court or authority, or any payment system (including, without limitation, bank payment systems, card payment systems such as Visa, MasterCard, or any other payment, clearing or settlement system, or similar agreement used to provide the Service/Services).

All capitalized terms used in this Anti-Fraud Policy and not otherwise defined have the same meanings as in the Terms of Use

    Terms of Use
  1. Terms
    1. In order to provide an appropriate and timely level of service and customer service, the Company must comply with the requirements contained in domestic and international laws on the prevention of money laundering and terrorist financing, as well as the requirements of other laws and regulations to the extent that they are related to the Company's activities.
    2. In order to implement the procedures provided for in this Policy, the Company develops and implements an internal system for assessing the level of risks of the client and their operations, defines the minimum required set of requirements, procedures, mechanisms, reports, systems and control measures for the Company's risk management. For high-risk customers and transactions, stricter procedures apply.
    3. The Company may make changes and additions to the Policy at its discretion (as new risks are identified and identified, new products/services/services are introduced, changes in current legislation) and will monitor compliance with its provisions and requirements.
  2. "Know your customer" procedures
    1. The Company carries out "Know Your Customer" (KYC) verification procedures to avoid the risk of prosecution for violations of applicable laws and to protect itself from the Client's attempts to use the Company and/or its services and/or service to carry out illegal actions, including those aimed at financing of terrorism or for the purpose of money laundering.
    2. As part of KYC procedures, the Company:
      1. establishes the identity of its client - studies its Client during the establishment of a relationship and clarifies information about him in time for his service. The Company performs identification procedures for the Client:
        • during the establishment of relations;
        • annually for high-risk clients, once every two years for medium-risk clients, once every three years for low-risk clients;
      1. studies the nature of the client's activities (the main goal is to make sure that the source of the client's funds is legal).
        - studies and evaluates Client transactions in order to assess the money laundering risks associated with this client in order to monitor the client's activities
      2. collects and stores information about Clients, the results of their studies, as well as material facts relating to Clients, potential Clients and their transactions.
    3. In order to identify the Clients, the Company requests the following documents:
    4. For individuals (depending on the type of product/access to products and services): contact information:
      • - nickname in the messenger (Telegram);
      • - phone number;
      • - Email address.

      identity documents:

      • - domestic and/or foreign passport;
      • - identity card, ID card;
      • - driver's license.

      documents confirming the address of residence/registration:

      • - a copy of the utility bill;
      • - a copy of the phone bill;
      • - Copy of the electricity bill;
      • - Bank statement.

      other documents, if necessary

    5. Due comprehensive verification of Clients.

      In the process of studying Customers, the Company can perform three levels of verification:

      - Simplified Due Diligence (“SDD”) are situations where the risk of money laundering or terrorist financing is low and full due diligence is not required. For example, accounts with low turnover and transaction amounts.

      - Basic Customer Due Diligence (CDD) is information obtained from all customers to verify the customer's identity and assess the risks associated with that customer.

      - Enhanced Due Diligence (“EDD”) is additional information collected about higher-risk customers to provide a deeper understanding of the activities of such customers in order to reduce the risks associated with them.

    6. The Company does not establish relationships with or accept services for clients who are identified as PEPs or are PEPs.
    7. After carrying out identification procedures related to the Client, the Company keeps the information obtained in the file of this Client.
    8. The company strives to protect the rights of the Clients and the confidentiality of their personal data. The Company collects personal information from Clients only to the extent necessary to ensure proper provision of services to Clients. Such personal information about Customers and former Customers may be transferred to third parties only in a limited number of circumstances in accordance with applicable laws and/or requests of competent authorities or in accordance with the Terms of Use and/or Privacy Policy.
    9. The Company carefully preserves the Client's files, including statements, transaction reports, receipts, notes, internal correspondence and any other documents relating to the Client, in electronic format for as long as necessary, in case they may be required by the underwriting teams in relevant acquiring banks/processors used by the Client, payment agents involved in transactions, law enforcement and/or other government authorities, etc.
    10. The Company has the right to suspend an Account associated with suspicious activity (including, but not limited to, activity that can be defined as money laundering, terrorist financing, embezzlement, etc.) and request the holder of such Account to undergo an in-depth KYC procedure ( request additional documents). In the event that the Client does not provide the necessary documents or the provided documents are insufficient to remove the suspicion of suspicious activity, the Company has the right to suspend the maintenance of the client's account/operations temporarily or indefinitely, including until the account is completely blocked and all assets are blocked.
  3. Detection and detection of suspicious activity
    1. Any financial transaction that may be related to money laundering, terrorist financing, violation of sanctions restrictions, scams is considered suspicious.
    2. The company independently develops and implements a mechanism for detecting such operations, a system and definition of Red flags, a criterion for determining risks. The basis for determining that a specific transaction is suspicious may be personal observations and experience of the Company's employees, information obtained during KYC procedures, information obtained using specialized analytical programs and/or systems, etc.
    3. The company regularly monitors the transactional activities of its clients, updates the systems and Red flags criteria used to identify suspicious activities, implements international best practices for identifying suspicious activities.
    4. In accordance with applicable laws and requirements of competent international organizations, the Company may, where appropriate, and without the obligation to obtain approval or notice from the Client, notify regulatory and/or law enforcement authorities of any suspicious transactions, as well as provide necessary information in response to requests from such organizations.
    5. When studying Clients and analyzing their operations, companies use the following lists:

      - sanctioned persons, known terrorists and/or terrorist organizations, or persons suspected of terrorist activities, published by local authorities and international organizations - OFAC (Office of Foreign Assets Control), EU, Ukraine, UN, etc.,

      - jurisdictions that do not provide a sufficient level of anti-money laundering procedures, in accordance with FATF policies, as well as countries subject to OFAC, EU, Ukraine, UN, etc. sanctions,

      - high-risk countries Annex 1 to determine whether the Company's Client is included or a potential Client and/or country/jurisdiction of such Client in the above lists, cooperation with which is prohibited or undesirable.

    6. The Company constantly conducts due diligence procedures on its Customers and scrutinizes their transactions to ensure that these transactions are compatible with the Company's knowledge of its Customers, their business and, where applicable, their source of income.
    7. The Company does not establish relations with Clients who are included in the sanctions lists or registered/located in the territories/jurisdictions specified in clause 3.5. or are under the control of such persons.
    8. If the Client is found to be unacceptably high risk, the Company may refuse such Client further service.
  4. Third parties
    1. To perform some of its business functions, the Company may engage third-party service providers or interact with counterparties. The Company makes every effort to investigate such service provider/contractor and its activities and to determine, to the extent possible, its reputation (whether there are any initiated investigations and lawsuits against any such third party service providers). The Company also determines whether the third-party provider has obtained all necessary licenses, permits and approvals before entering into a business relationship with such third-party service provider.
    2. The company does not establish relations with service providers and/or counterparties that are included in sanctions lists or registered/located in the territories/jurisdictions specified in clause 3.5. or which are under the control of such persons.
  5. Training of employees and representatives.
    1. The Company takes all possible measures to train employees in order to prevent the company from engaging in actions aimed at using the Company and/or the Company's Services for the purpose of money laundering, terrorist financing, fraud or violation of established sanctions restrictions.
    2. The company can conduct training of employees in the form of electronic courses, online webinars, face-to-face seminars and any other way that will allow to convey the necessary information to employees and, if necessary, to check the acquired knowledge.
    3. Regarding its own personnel, the Company takes all possible measures to thoroughly analyze all job candidates in order to determine whether the activity and/or reputation of a new employee falls into a category that is prone to or carries risks of money laundering.
  6. Reporting of suspicious transactions and risky customers.

    The Company develops and implements internal reporting that allows receiving timely information about the Company's risks and their management. If an employee of the Company becomes aware of an activity that is subject to the restrictions specified in the Policy, such an employee must immediately report such an event and provide all necessary information to his manager and/or authorized department (compliance) and/or senior management of the company.

  7. User agreement
    1. By using the Services/Company Service, you warrant that you do not intend to engage in any of the prohibited activities described herein; in addition, you consent to any checks related to the conduct of an investigation under the Anti-Fraud Policy and agree to fully and promptly cooperate with the Anti-Fraud Officer in such investigation. Failure to cooperate or provide the required information/documents may be grounds for termination of your service or complete refusal of further service.
  8. Final provisions.
    1. This program is approved in the order provided by the >> Site << company and approved by the >> Site << Company Management.
    2. This Policy takes effect from the moment of approval and/or publication on the >>Site<<.

Appendix 1
to the client's risk management policy,
money laundering and financing of terrorism, sanctions and countries
(AML/CTF & KYC & SANCTIONS & COUNTRY)
List of countries/jurisdictions and territories
with a high level of risk
cooperation with whom is prohibited or undesirable