Anti-money laundering and know-your-customer policy notice

1. Definitions

• AML (Anti-Money Laundering): A set of activities, procedures, and regulations designed to prevent criminal activities related to money laundering.

• CFT (Combating the Financing of Terrorism): A set of activities, procedures, and regulations created to prevent criminal activities related to terrorism.

• Financing of Terrorism: A crime against public safety consisting of collecting, transferring, or offering property values to finance a terrorist crime or making property values available to a person or an organized group aimed at committing such an offense.

• GIIF (General Inspector of Financial Information): A government administration body responsible for countering money laundering and terrorist financing.

• Obliged Institution: Entrepreneurs, companies, and institutions that are obliged to analyze transactions and provide the GIIF with information on suspicious transactions.

• Clients: Natural persons to whom the Company provides services or for whom it performs activities within the scope of its professional activity.

• Politically Exposed Person (PEP): An individual who holds a significant position or public office.

• Employee: A natural person performing duties for the obliged institution (the Company).

• Money Laundering: An activity aimed at introducing money from illegal sources into legal circulation or using it to finance illegal activity.

• Transaction: A legal or factual act by which ownership or possession of property values is transferred or a legal or factual act performed for the purpose of transferring ownership or possession of property values.

2. Purposes and Basis

The purpose of this AML & KYC Policy is to introduce financial security measures and other obligations in accordance with the Law on Anti-Money Laundering and Financing of Terrorism. The policy aims to prevent the use of the Company's services in an unlawful manner.

3. Scope of Application

This AML & KYC Policy applies to all Clients trading on the Paynamic website. By creating an account on the Website, the Client voluntarily and fully acknowledges the Company's AML Policy and agrees to abide by its AML and KYC procedures.

4. AML Measures

The Company sets the following AML measures:

4.1. Client Identity Verification: Before entering a business relationship, the client's identity must be verified.

4.2. Risk-Based Client Due Diligence: Implementing and maintaining risk-based client due diligence, including enhanced due diligence for clients who pose higher risks.

4.3. Transaction Monitoring: Monitoring transactions based on risk analysis.

4.4. Reporting Suspicious Activity: Reporting suspicious activity internally and to the relevant authorities if required by applicable laws and regulations.

4.5. Regular AML Training: Providing regular AML training for the team.

5. KYC Procedures

The Company has established Know Your Customer (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow the Company to identify every Client, understand the legitimacy of business relationships, and identify and react to unusual or suspicious activity.

6. Purposes of KYC

By collecting and reviewing Client data, the Company commits to:

• Establishing the identity of Clients.

• Checking that Clients are not considered high-risk.

• Monitoring transactions for unusual or suspicious activity.

7. Client's Due Diligence

7.1. Simplified Due Diligence

Simplified due diligence measures may be applied where a risk assessment confirms a lower risk of money laundering or terrorist financing.

7.2. Enhanced Due Diligence

Enhanced due diligence measures shall apply where there is a higher risk of money laundering or terrorist financing, especially for customers from or established in a high-risk third country.

8. Client's Identity Verification

The Client is required to provide:

• Full name.

• State-assigned identification number (supported by documents such as a photocopy of a national ID, international passport, or other ID documents).

• Date of birth.

• Nationality.

• Telephone number.

• Email.

• Address (supported by documents such as a bank statement and utility bill as proof of address).

• Other information or documents requested by the Company (photo of the Client, documents confirming the source of funds, etc.).

9. Sanctions and PEP Lists Screening

PEPs may constitute an additional factor of risk. The Company screens Clients against Sanctions and Politically Exposed Persons (PEPs) lists using third-party screening tools.

10. Jurisdiction Restrictions

Client domicile is considered one of the factors associated with customer risk analysis. The Company provides verification of the country of residence of the Client regarding:

• Degree of corruption (clash with corruption maps).

• Deviation of the place of residence or domicile from the usual customer.

• Residence in a tax haven (countries applying harmful tax competition).

• Origin from high-risk countries designated by the European Commission and FATF or recognized as such by the obliged institution.

11. Banned Countries

Clients and traffic from the following countries are banned from using Company services:

Afghanistan, Albania, Algeria, Angola, Argentina, Bahrain, Bangladesh, Barbados, Belarus, Benin, Bhutan, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Burkina Faso, Burundi, Cambodia, Cameroon, Cape Verde, Central African Republic, Chad, China, Colombia, Comoros, Congo DR, Costa Rica, Crimea region, Cuba, Djibouti, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Ethiopia, Fiji, Gabon, Ghana, Guatemala, Guinea, Haiti, Honduras, Iran, Iraq, Jamaica, Jordan, Kenya, Kosovo, Kuwait, Laos, Lebanon, Liberia, Libya, Macedonia FYR, Madagascar, Malawi, Maldives, Mali, Mexico, Morocco, Myanmar, Namibia, Nepal, Niger, Nigeria, North Korea, Northern Cyprus, Oman, Pakistan, Palau, Panama, Paraguay, Peru, Puerto Rico, Qatar, Russia, Rwanda, Somalia, Senegal, South Sudan, Sudan and Darfur, Syria, Tanzania, Togo, Trinidad & Tobago, Tunisia, Tuvalu, USA, Vanuatu, Vatican City, Venezuela, Yemen, Zambia, Zimbabwe.

12. Client’s Transactions and Card Verification

If seizure of transactions is inconsistent with the client's business profile, it should be included in the risk assessment. The Company can request proof of the source of funds, the purpose, and the intended nature of the transaction. Bank account number and credit/debit card information are needed for the card verification process only.

13. Low-Risk Clients

Low risk may be indicated if the Client is:

• A resident of a member state of the European Union or a member state of EFTA - a party to the EEA Agreement.

• A resident of a third country that is determined by reliable sources to be a country with a low level of corruption or other criminal activity.

• A resident of a third country where, according to reliable sources, AML/CFT regulations are in force.

14. High-Risk Clients

High risk occurs in particular when:

• The Company doubts the authenticity, validity, and/or integrity of the Client’s identity information.

• The Client is from or based in a high-risk third country.

• The Client has PEP status.

• The transaction has the status of an unusual transaction.

• There is suspicious conduct on the part of the Client.

15. Termination of Services

If Clients are considered high-risk for any reason, the Company reserves the right to reject the client’s documents, request additional documents and information, cancel any payments and transfers, or block or close the account.

16. Compliance Officer

The management board of the Company has appointed an AML officer, whose responsibilities include gathering and studying data on transactions and circumstances related to money laundering or terrorist financing. The officer is also responsible for ensuring compliance with statutory regulations, employee education and training, and reporting to authorities in the event of suspicion of money laundering or terrorist financing.

17. Confidentiality

Any Paynamic employee who obtains information related to anti-money laundering while performing their duties must adhere strictly to confidentiality obligations and maintain the privacy of all Client information. All Client data are collected and stored in accordance with our Privacy Policy and applicable laws and regulations.

18. Information Requests

For more information on this AML & KYC Policy, please contact us at [email protected].