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1. OBJECTIVE OF THE AML POLICY

Our company is abiding by the anti-money laundering (AML) requirements applicable to our type of business. To manage and reduce the risk of our company being used by criminal elements, all our staff is focusing on pursuing the highest standards of AML and Know Your Customer (KYC) regulations.

To make sure that all the necessary steps are taken to achieve the full safety of our services, we have implemented the framework of AML Policy. In this AML Policy we are committed to follow the provisions specified in the Estonian AML laws, EU and international AML guidelines.

2. WHAT IS AML POLICY?

AML Policy is the set of rules we put in place to make sure our services are not being used for money laundering, terrorist financing or any other type of criminal activity. KYC measures are part of the AML Policy. These are meant to empower businesses, by helping them to know and understand their customers better and manage the specific risks. KYC procedures are susceptible to be updated in the future, to make sure compliance with the existing laws and best AML practice is perfected.

If any potentially suspicious or unusual transactions or customer’s behavior arise, we undertake the appropriate measures to address the risks. Additional documents, such as proof of funds’ sources etc, might be asked from the customers, by staff handling transactions. When it comes to keeping records, we have put in place a well-organized procedure, to ensure all identification documents and data related to transactions is stored confidentially and according to personal data protection laws.

Our AML Policy comprises:

- Customer identification and verification before starting a commercial business relationship.

- Establishing and maintaining the risk-based customer due diligence including enhanced due diligence for high risk customers.

- Transactions monitoring of the client’s financial behavior, following risk-based analysis.

- Regulations about how to report suspicious activity internally and to the required law enforcement authorities.

- Periodical AML staff trainings.

We are forced to reject the customer’s documents, close their account and terminate the business relationship in case any suspicious activity is found, if the customer provides false documents or fails to cooperate with the company during the customer due diligence process.

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