AML POLICY CRYPTOPAYMENTS

The process by which individuals or entities disguise the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions.

The process of providing financial support to individuals or groups that engage in terrorism or terrorist activities.

Know Your Customer (KYC) Procedures: Cryptopayments performs comprehensive KYC procedures to confirm the identity of all customers and evaluate the risk associated with their transactions. This process involves collecting identification documents, verifying their authenticity, and cross-referencing customers against relevant sanctions and watchlists.

Know Your Business (KYB) Procedures: In addition to KYC, Cryptopayments conducts KYB procedures to verify the identity and legitimacy of business entities. This includes obtaining and validating business registration documents, verifying ownership and management structures, and screening against relevant databases to ensure compliance with regulatory standards.

Enhanced Due Diligence (EDD): For customers identified as higher risk, Cryptopayments implements enhanced due diligence measures. This includes gathering additional information, screening for politically exposed persons, and applying appropriate risk-mitigation strategies.

Cryptopayments employ robust transaction monitoring systems to detect and report suspicious activities. This includes monitoring transactions for unusual patterns, large or rapid transfers of funds, and transactions involving high-risk jurisdictions. Additionally, our compliance team conducts manual reviews of flagged transactions to assess their legitimacy. This may involve contacting customers for additional information or documentation to support the transaction.

Cryptopayments employs a risk-based approach to due diligence by gathering comprehensive information and documentation on prospective clients to evaluate their risk profiles.

To identify, assess, and analyze risks associated with money laundering and terrorist financing, the Company conducts a risk assessment that considers the following categories:

1. Customer Risk
2. Geographical Risk
3. Product Risk
4. Delivery Channel Risk

Once the risk level is determined for a customer, it is periodically reviewed and updated based on ongoing knowledge of the customer and their activities.

Sanctions are a crucial foreign policy instrument used to promote and uphold peace, international security, democracy, and the rule of law, as well as to advance human rights, international law, and the objectives outlined in the United Nations Charter or the European Union's common foreign and security policy. When sanctions are imposed, altered, or lifted, Cryptopayments will check whether the User, Beneficial Owner, or anyone planning to engage in a business relationship or transaction with them is affected by these sanctions. Cryptopayments will also determine the specific sanctions measures applied to the individual to implement the appropriate actions.

Cryptopayments gathers and maintains documents and data regarding the User, including their transactions and activities, both during and after the KYC/KYB verification process. This also includes cases where Cryptopayments was unable to complete CDD and details surrounding the termination of any business relationship. Additionally, Cryptopayments keeps records related to reporting obligations and the correspondence with the Users. All data is stored in compliance with the minimum retention periods required by applicable laws.

Beneficial Owner is an individual who exerts control over or benefits from a transaction, act, or operation, either directly or indirectly. In the case of a legal entity, a Beneficial Owner is someone who holds more than 25% of the entity, either through shares or other forms of ownership.

Politically Exposed Person (PEP) is defined as an individual who is or has been entrusted with prominent public functions. Due to their position and influence, PEPs are considered higher risk for potential involvement in bribery, corruption, and money laundering.

The definition of PEPs includes:

Foreign PEPs: Individuals who are or have been entrusted with prominent public functions by a foreign country, such as heads of state or government, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials.
Domestic PEPs: Individuals who are or have been entrusted with prominent public functions domestically, with similar roles to those of foreign PEPs but within the country.

International Organization PEPs: Individuals who are or have been entrusted with prominent functions by an international organization, such as members of senior management or individuals with significant decision-making authority within the organization.

Family Members and Close Associates: The definition of a PEP also extends to family members and close associates of individuals who hold or have held these positions. This includes spouses, children, parents, and siblings, as well as close associates like personal advisors or business partners.

Cryptopayments regularly review and update its AML Policy and procedures to reflect changes in regulatory requirements, emerging risks, and industry best practices. We conduct internal audits and assessments to ensure compliance with the AML Policy and identify areas for improvement.

The KYB process typically involves verifying the company’s legal existence, ownership structure, and the identities of its directors, beneficial owners. 1. Certificate of incorporation/registration This document proves that the company has been officially registered with the relevant government authority.

2.Memorandum & Articles of Association were signed by the company’s director These documents outline the company's constitution, rules, and regulations governing its internal affairs.

3.Certificate of Incumbency This document typically includes details about the current directors, officers, and shareholders of the company. It is often used to confirm the individuals authorized to act on behalf of the company.

4.Certificate of Good Standing This certificate attests that the company is in compliance with all statutory requirements and is authorised to conduct business. It may also be known as a Certificate of Existence or Certificate of Status.

Any documents submitted must be in English, or if in another language, they must be accompanied by a notarized translation. For EU/EFTA/Switzerland registration, apostilles may not be necessary. Additionally, registration documents should not exceed a 12-month age limit.

*Countries not party to the Hague Convention will be required to provide documents notarized with an English translation.