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Updated on Nov 03, 2022

AML Policy

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1. Introduction

1.1. Purpose

A major commitment of the Cryptoro OU's and its subsidiaries (hereinafter “the Group”) is to maintain the highest level of ethical and professional behavior, having zero tolerance towards illegal and irregular acts affecting its reputation and credibility.

The AML/CFT Policy of the Group is issued to ensure the carrying out of activities in compliance with the national and international legal requirements and the legislation regarding Anti Money Laundering and Terrorism financing, to ensure the observance of the prudential practices and to promote high ethical and professional standards and prevent the Group from being used intentionally or unintentionally in illegal or criminal activities performed by its customers.

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Money laundering is:

● the conversion or transfer of property, knowing that such property

is derived from criminal activity or an act of participation in such activity, to conceal or disguise the illicit origin of the property or of assisting any person involved in the commission of

such activity to evade the legal consequences of his actions;

● concealing or disguising the true nature, sources, locations, dispositions, movements, and rights in regards to assets or ownership of property, knowing that such property is derived from criminal activity or an act of participation in such activity;

● the acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or an act of participation in such activity;

● participation, association to commit, attempts to commit, and aiding, abetting, facilitating, and counselling the commission of any of the acts referred to in the preceding paragraphs.

Terrorist financing is the provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, to commit any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13th of June 2002 on combating terrorism.

1.2. Scope

This policy applies to all Cryptoro OU activities, including the Konto Exchange activity.

It applies to the following people and entities:

● The governing bodies of Cryptoro OU and any subsidiaries of Cryptoro OU, staff and consultants of Cryptoro OU group companies, regardless of their position, rank, or seniority (hereinafter referred to as"Cryptoro OU governing bodies and staff");

● Contractors, subcontractors, consultants, suppliers, beneficiaries, and, in general, relevant people or entities involved in the activities of Cryptoro OU and Konto Exchange (hereinafter referred to as the "Project Parties");

● Consultants, suppliers, service providers, and other people or entities in which Cryptoro OU holds equity interests or which are wholly or partially owned by Cryptoro OU; and

● All counterparties and other people through whom Cryptoro OU conducts business (collectively referred to herein as "Cryptoro OU's other counterparties and partners").

2. Policy principles and rules

2.1. Risk Management Activities

The primary purpose of the risk management approach is to ensure the identification, assessment, scoring of risks, action planning, and mitigation of the potential risks the Group may be exposed to, concerning the laundering of proceeds of crime and financing of terrorism. To that end, the Group has developed procedures like “Know Your Customer”.

2.1.1. KYC

Accordingly, the Group performs necessary controls and takes additional measures for the identification and verification of the identity and address details of (potential) customers; the consistency of the income levels of customers, the sources of income of the customer; the possibility of the customers being included on national/international sanctions lists, etc.

The Group does not establish any business relations or perform the transaction requested if the proof of identification and verification is not made or sufficient information about the purpose of the business relations is not obtained, and the business relationship will be terminated when the identification and verification of the customer are not performed where it is required to be conducted in case of any suspicion related to sufficiency and accuracy/authenticity of the previously obtained identity details of the customer.

The standard customer due diligence process to be performed by the Group, at a minimum, as part of “Know your customer” measures include:

- Identification and verification/authentication of the customer’s identity details, ultimate beneficial owners, authorized representatives under legal legislation and internal policies,

- Screening of the customers in case of the risk of them being on international sanctions lists,

- Determination of whether the customer and any related parties of the customer are a politically exposed person (PEP), or related/linked to a politically exposed person,

- Determination of whether the customer acts on behalf and/or account of other persons.

Enhanced due diligence measures are applied for customers during customer acceptance processes or subsequently. Enhanced due diligence involves the gathering of additional information to ensure that the person or entity is not participating in any improper or illicit conduct. This information should include but is not limited to, the source of the funds, the source of the individual or company’s wealth, and the individual’s occupation or the type of business.

2.1.2. Risk Assessment Methodology

All customers undergo an assessment process in respect of the potential risks of laundering proceeds of crime and the associated risks as part of the minimum standards set out under the AML/CFT Policy.

2.2. Monitoring and Control Activities

For the prevention of money laundering and of proceeds of crime and financing of terrorism, the Group carries out an ongoing monitoring and control process, mainly, concerning: High-risk customers and transactions, transactions with risky countries, and complex and unusual transactions.

2.3. Reporting of suspicious transactions

Suspicious transaction means the presence of any information, suspicion, or any matter which would require suspicion about the fact that the assets subject to a transaction, performed or attempted to be performed with or through the Group’s products, have been obtained illegally, or are used for unlawful purposes, or are used by any terrorist organizations, terrorists or financiers of terrorism within such scope, or are related or associated with them.

The Group shall not provide any information to any person, including the persons who are a party to the relevant transaction, other than the information provided to the courts during any trial or the authorities as required by laws and regulations.

2.4. Retention of documentation

The Group retains any documents associated with its obligations in line with the requirements of the applicable laws and regulations and the relevant legislation on GDPR.

2.5. Training activities

Training activities are planned in coordination with internal procedures and organized for the entire staff of the Group as on-site (classroom learning) or off-site (e-learning programs, reminders, and awareness messages).

3. Final provisions

The Compliance Department is responsible for the evaluation and annual review of the Policy and, if deemed necessary, proposes amendments to recognize changes in the respective regulatory framework and continually improve operational efficiency and effectiveness.

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Whistleblowing Form
Speak Up!

We have a strong commitment to building and maintaining a culture of transparency, honesty and trust within our organization at all times.

We also have a duty of care to all of our teams, customers, partners and other stakeholders, and we take these responsibilities very seriously. It is for these reasons that you are encouraged to speak up if you believe that we are not living up to our commitments and report any behavior that you believe to be unethical, illegal or fundamentally inappropriate.

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Konto.com is a property of Cryptoro OU group and is operated by: Rondo Services Sp. z o.o., a company incorporated under the laws of Poland, with its registered address in Warsaw, Ul. Hoza 86 / 210, registered into the Register of Business within Virtual Currencies under the authority of the Director of the Inland Revenue Administration Chamber in Katowice under number RDWW-255. Nava Investment UAB, a company incorporated under the laws of Lithuania, with its registered address in Kaunas, Chemijos g. 27C,registered as a virtual asset service provider under the authority of Financial Crime Investigation Service (FNTT) under the number 306112062. Rondo Services Sp. z. o.o. Warsaw Cluj-Napoca, Romania branch, registered at the National Office for the Prevention and Control of Money Laundering (ONPCSB) as a provider of virtual and fiat currency exchange services and as a provider of digital wallets under the number 3113/2023.

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