AML POLICY

A. ANTI-MONEY LAUNDERING

This policy is to establish guidelines for UAB BANQEO EXCHANGE (“Company”) ‘Anti-Money Laundering’ and ‘Know Your Client’ (“KYC”) procedures for new and existing clients.

All of monetary transactions, to the best knowledge of the Company shall be free from any form of money laundering and terrorist activities. The Company operates with integrity and is committed to implementing the measures established. The Client’s failure to comply with the regulations set by the Company would mean termination of the account. If the Client is proven of committing money laundering, he is responsible for any damage or loss which may occur, and the Company is excluded from his fraudulent actions.

In an effort to counter money laundering and other illegal activity, we have decided not to support any cash transactions, regardless of their stated purpose. Our firm has the right to cancel or deny a transaction at any point if there are suspicions regarding its legality.

General Measures

It is the Company’s AML Policy to apply to all clients the below mentioned general measures:

• check the identity of the Client
• monitor any suspicious Client activities and/or transactions
• have a record of all the related information and/or documents of the Client’s financial transactions

The Company’s KYC and due diligence procedures are applied by the Company’s Back Office when accepting clients to open exchange accounts.

Restricted Business and Jurisdictions

Our Company does not provide services to clients that their activities are associated with any high risk or banned activities. Furthermore, the Company does not accept clients from high risk countries, including but not limited to the following countries:

• Cuba
• Iran
• North Korea
• Syria
• United States

Furthermore, the Company does not accept clients from high-risk countries as per the guidelines of FATF http://www.fatf-gafi.org/countries/ which is updated accordingly.

B. KYC PROCEDURE

The KYC procedure is a requirement in order to comply with the International law provisions, including the ones designed to prevent money laundering. The following should be followed unless an amendment is sent from the Compliance Department stating otherwise.

When a client applies to open an account with us it is the Company’s duty to ensure that along with the application the following documents are received:

Natural Persons – (this also applies to natural persons involved in a legal entity such as Directors, Shareholders or authorized persons)

  1. Proof of Identity (POI)

Is any document which may be used to prove a person’s identity. It should be valid. For European citizens, an Identification card is sufficient. For all other’s it should be a passport. In the absence of the passport, the identification with a driving license will be accepted instead.

  2. Proof of Residence (POR)

• A proof of residence is a document confirming where the client lives. It needs to have both the name of the individual and his/her address printed on it. Such documents are: Recent Utility Bill. This can be water bill, electricity bill, bank statement or bank reference letter, tax bill, municipality bill where home address is shown or,
• Bank Statement or
• Local Authority Tax Bill or
• Any other official document same with the abovementioned.

  3. Proof of Bank Account Ownership

If a new client wishes to exchange Cryptocurrency to FIAT, he must also provide proof of ownership of account. Such document is a bank statement where the name and the address match the company’s records

Corporate Accounts

When a legal entity wishes to open an account with UAB BANQEO EXCHANGE the below must be collected:

• Company’s Incorporation Documents
  • Certificate of incorporation or equivalent
  • Certificate of registered office or equivalent
  • Certificate of directors and secretary or equivalent
  • Certificate of shareholders or equivalent
  • Memorandum and articles of association of the legal person
  • Recent copy (up to three months) of a bank statement or utility bill in order to verify the head office address
  • Identity of Directors and Shareholders with their relevant KYC documents required of Natural Persons
  • Authorized person resolution signed by the Board of directors (‘BoD’)

Additional Documents

Depending on the amount the client wishes to exchange, the Company has formed Tiers where the required documentation differ. These Tiers are:

Tier 1

• Up to 5,000
  • PoR
  • PoI

Tier 2

• Between 5,000 – 10,000
  • PoR
  • PoI
  • Questionnaire

Tier 3

• Above 10,000
  • PoR
  • PoI
  • Questionnaire
  • Source of funds
  • State of Work Agreement

Recordkeeping

Assessment of client documents will be made on an annual basis. All client’s documents and record transactions will be kept safely and back-up for a minimum five (5) year period.

C. TRANSFER OF FUNDS

General Practice

When transferring money for purchasing digital currency, the sender’s name and the information held on file, should match.

Money transfers from another party other than the account holder is strictly prohibited.

Furthermore, we will refuse any third-party transfers towards one of our Clients.

In case there is any discrepancy on a transaction, we reserve the right to automatically cancel or suspend the transaction. Further to this, third parties are forbidden to conduct the transaction in replace of the Client.

Important Notes

• Have the Senior Management approval prior of opening a “Political Exposed Person” account.
• When a PEP is a potential client we need to obtain a bank reference letter.
• Where the documents are not in English:
  • We need translation from a translator (external and/or an employee of the Company).
  • If there is no one to translate the documents, we ask the client to send us an official translation from a notary.

UAB BANQEO EXCHANGE has the right to refuse any client without giving reason.

These guidelines have been implemented to protect UAB BANQEO EXCHANGE and its clients.