Effective Date: 28.02.2024
1. Activities and actions to reduce the risk of money laundering, terrorist
financing and to properly manage the identified risks of money
laundering or terrorist financing:
The purpose of the procedure is to introduce in the obliged institution
financial security measures and other obligations stipulated by the
regulations, in accordance with the Law on Anti-Money Laundering and
Financing of Terrorism. The procedure contains a set of internal
regulations, which are undertaken in the obliged institution in cooperation
with dedicated state and international authorities to combat and prevent
the above crimes. Since the aim of the obliged institution is to operate
transparently, in accordance with the law and the principles of social
coexistence, this procedure is intended to prevent the use of its services
in an unlawful manner. The procedure therefore applies to employees,
co-workers as well as contract, temporary or agency workers, interns,
volunteers, and trainees (hereinafter all collectively "co-workers"). The
primary activities and actions to meet the statutory obligations are the
application of financial security measures and ongoing risk analysis to
prevent money laundering or terrorist financing.
Company provide P2P services in the virtual assets field, such as
exchange virtual assets to fiat and vice versa.
Company does not provide services of exchange of fiduciary currency
into another fiduciary currency and payment services in accordance with
the Payment Services Act (the entity, in particular, does not accept
deposits and does not transfer funds)
1) Definitions
AML (anti-money laundering) - anti-money laundering - a set of
activities, procedures, and regulations designed to prevent criminal
activities related to money laundering.
Ultimate Beneficial Owner - a natural person or natural persons
exercising direct or indirect control over the client through their powers
that result from legal or factual circumstances, enabling them to exert a
decisive influence on the activities or actions undertaken by the client or
natural person, or natural persons, on behalf of whose business relations
are established or an occasional transaction is carried out;
Close associate of PEP - a natural person who is the beneficial owner of
a legal person, an organizational unit without legal personality or a trust
jointly with PEP or having other close relationships with it related to the
conducted business activity, as well as a natural person who is the sole
beneficial owner of legal persons, organizational units without legal
personality or a trust, known to have been created for the purpose of
obtaining an actual benefit by the PEP;
Account blockade - temporarily prevention of the use and disposition of
all or part of the assets accumulated in an account (where the obligated
institution provides account maintenance services).
PEP family member - spouse or cohabiting person, child of PEP or his
spouse or cohabiting person, parents.
CFT (combating the financing of terrorism) - counteracting the financing
of terrorism - a set of activities, procedures and regulations created in
order to prevent criminal activities related to terrorism.
Financing of terrorism - a crime against public safety consisting in
collecting, transferring, or offering property values in order to finance a
terrorist crime or making property values available to a person, an
organized group aimed at committing such an offense (in detail the act
specified in Article 165a of the Act of 6 June 1997 Criminal Code).
FAU - Financial Analytical Unit, a government administration body
responsible for counteracting money laundering and terrorist financing.
Obliged institution - entrepreneurs, companies and institutions that are
obliged to analyze transactions and provide the FAU with information on
suspicious transactions.
Senior Management - A board member, director, or employee of an
obligated institution with AML/CFT expertise related to the
organization's operations and decision-making impacting risk and as
such, responsible for carrying out statutory obligations.
Customer - natural person, legal person, or organizational unit without
legal personality, to whom organization provides services or for whom it
performs activities falling within the scope of its professional activity
(including with whom organization establishes economic relations or on
whose behalf it carries out occasional transaction).
Politically Exposed Person (hereinafter PEP) - an individual who holds a
significant position or public office.
Employee - a natural person performing duties for the obliged institution
regardless of the legal form on the basis, of which the cooperation was
established (employment contract, contract of mandate, cooperation
agreement and others).
Money laundering - an activity aimed at introducing to the legal turnover
of money originating from illegal sources or used for financing illegal
activity (in detail, Act No. 253/2008 Coll., on certain measures against
money laundering and financing of terrorism and Decree No. 281/2008
Coll., on certain requirements for the system of internal policies,
procedures and control measures against money laundering and terrorist
financing).
Information processing - any operation performed on information, in
particular its acquisition, collection, consolidation, storage, editing,
sharing and deletion (the term also includes information stored in an IT
system).
Economic relations - the relationship of the organization with the
customer related to the professional activities of the company, which at
the time of its establishment show the characteristic of permanence.
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.
Occasional transaction - a transaction conducted not in the context of a
business relationship.
Act - the Act of March 1, 2018, on counteracting money laundering and
financing of terrorism.
Property values - property rights or other movable property, real estate,
means of payment, financial instruments, other securities, foreign
exchange, virtual currencies (including cryptocurrencies).
Suspension of transactions - a temporary restriction on the use and
disposition of property by preventing a single transaction or more
transactions from taking place.
Board of directors - the person authorized to represent the obligated
institution, including when the board of directors is not formally appointed
or does not exist for reasons of organizational form
2) Responsibilities of senior management
a) Establishes the scope of competences for those responsible for
implementing and maintaining an effective anti-money laundering
and counter-terrorist financing system, and fulfills the statutory
obligations listed in the AML/CFT Act.
b) Establishes a budget to support and develop an internal AML/CFT
system.
c) Approves the training plan and expenditures for training and
competency enhancement.
d) Is responsible for building awareness among employees and
associates in the field of anti-money laundering and counter-
terrorist financing and for adhering to the procedures and policies
implemented in the organization in this regard.
e) Frequency of employee training in order to comply with the current
legislation must be no less that once in 6 months.
3) The person responsible for performing the duties contained in the
procedure:
In the absence of a written designation and the acceptance of these duties
by another person, they shall be all members of the board of directors of
the obligated institution (senior management). This provision shall be
treated as the designation of the responsible person in accordance with
the statutory regulation. The primary person performing these duties is
the CEO or the owner of the obligated institution if the CEO has not been
singled out. The responsibilities include implementing statutory
regulations, ensuring compliance of the activities of the obligated
institution and its employees and other persons performing activities for
the entity, and providing notifications of statutory requirements.
4) Associates of the obligated institution:
a) comply with the AML/CFT policies and procedures implemented in
the organization.
b) take an active part in the risk assessment of the client, apply
financial security measures to the client.
c) ensure that operations conducted by the company are following the
law and meet AML/CFT security standards.
d) inform the person responsible for the compliance of the obliged
institution with the AML/CFT regulations and make available all
available data on circumstances of transactions indicating the
connection with money laundering or terrorist financing -
regardless of the size of transaction.
e) participate in anti-money laundering and counter-terrorist
financing training.
Accordingly, at the commencement of work/cooperation with the
obliged institution, these persons and persons performing duties
related to AML/CFT and familiarize themselves with this procedure
and receive training in the subject of anti-money laundering and
terrorist financing (possible in the form of an on-line video).
Confirmation of these activities is the submission of a statement,
possibly in accordance with Attachment 2.
2. Principles of identifying and assessing the risk of money laundering and
terrorist financing associated with a given business relationship or
occasional transaction, including the principles of verification, and
updating of previously made money laundering and terrorist financing risk
assessment.
1) Recognition
Means gathering information about the customer based on own
sources, publicly available information and based on information
and documents provided by the customer.
2) Risk assessment and risk documentation
Means classifying the customer to the appropriate risk category
(low, standard, high) on the basis of methodology developed and
applied in the organization.
Documenting the client's risk along with the assessment in the form
of a so-called Client File (may be maintained in electronic form),
which must include:
a) Type of customer,
b) Geographical area,
c) Type of products, services, services provided and their
distribution channels,
d) The level of assets held by the client or the value of the
transaction, if the client qualifies as a higher risk client,
e) Purpose, regularity, or duration of the business relationship.
3) Principles of verification of risk assessment
In order to determine the customer's risk, the following criteria
should be considered in particular:
a) Economic - assessment of the customer in terms of the purpose
of his business,
b) Geographical - analysis of the customer's transactions, its
business relations with entities from third countries, where
there is an increased risk of money laundering and terrorist
financing. The customer's place of residence or business should
also be assessed here.
c) Substantive - what type of activity does the client conduct, is it
a higher or high-risk activity from the point of view of
AML/CFT regulations?
d) Behavioral - unusual behavior of the customer in a given
situation.
The risk analysis considers:
a) Communications and training with the AML officer,
b) Annual reports of FAU,
c) National Risk Assessment,
d) European Commission report,
e) Corporate memory and experience of the obliged institution,
f) Media reports.
4) Client’s periodic review
Frequency of updating the customer risk assessment:
a) In the case of a low-risk customer - 5 years periodic review
b) In case of a customer with medium level of risk - 3 years
periodic review
c) In case of a customer with a high-risk level - 1 year periodic
review
d) And also, each time if the obliged institution becomes aware of
a change in significant issues that may affect the customer's
risk level.
5) Regular screening
AML officer is checking our users activity on the monthly basis,
including transaction monitoring, and if there is any suspicious
activity the AML officer may conduct name screening in order to
check legitimacy of our users. The actual name screening may
appear no more than twice a year.
6) Transactions monitoring
All transactions are carefully monitored by our AML officer
manually. We plan to implement integration with KYCaid
transaction monitoring AML tools and we notify our users and
partners when this will occur. Until then, the transactions are
monitored by our AML officer manually.. The threshold which user
have to exceed to apply additional screening is EUR 10,000 in
either single transaction or several during the month. AML officer
is conducting the monitoring of transactions on the daily basis to
verify users and then to monitor the transactions of such users. In
case if there is a suspicious transaction in place (over EUR 10,000
or a lot of small transactions during short period) we conducting an
additional check and in case if we cannot verify the source of funds
or such user our AML officer have to inform Financial analytical
Unit (FAU) regarding such transaction.
We are considering KYCaid LLC as our transaction monitoring
provider is. It is the outsourced service provider with whom we
have signed agreement.
The rules of the transaction monitoring (TM) are simple. Our
dedicated AML officer is monitoring transactions through the
KYCaid or other third-party tools implemented into our website. In
case if the EUR 10,000 threshold is exceeded either in single or in
several transactions from one user, the AML officer is sending the
additional verification link to such user. Through this link such a
user has to answer to additional questions and provide with
additional documents (source of funds, residency, agreements etc.)
The transactions will be monitored through the KYCaid or other
third-party AML/KYC provider we may choose by our in-hose
certified AML officer. Our AML officer is trained and certified and
go through additional trainings every 6 months. In case of
unusual/suspicious activity the AML officer have to contact user,
which conducted such unusual activity. In case if such user fails to
provide additional information, our AML officer have to report to
Czech Republic Financial Analytical Unit (FAU). As we just started
we have only one dedicated AML officer monitoring the
transactions.
We do not use any on-chain analysis tool to help detect illicit
activity on the blockchain.
We may implement a platform which is an automated transaction
monitoring system into our website. Additional transaction
monitoring policies will be implemented together with such a
platform solution.

3. Measures applied to properly manage the identified risk of money
laundering or terrorist financing related to the given economic relations
or occasional transaction
Characteristics of factors associated with the customer risk
analysis (sample listing):
a) Type of customer:
- a natural person,
- a natural person conducting a business activity,
- commercial law company,
- a commercial law company admitted to trading on a regulated
market,
- non-profit organization.
b) Business object - industry:
- scrap metal trading,
- fuel industry,
- services (e.g., car washes, laundries, restaurants),
- construction industry
c) Client domicile - verification of the country of residence of the
head office with respect to:
- degree of corruption (clash with corruption maps),
- deviation of the place of residence or domicile from the usual
customer,
- residence in tax haven (countries applying harmful tax
competition)
- origin from high-risk countries designated by the European
Commission (by which is meant the countries listed in the
Directive of the European Parliament and of the Council (EU)
2015/849 or any other legal act currently in force) or
recognized as such by the obliged institution, whereby as of the
date of introduction of the procedure is meant at least:

1 Afganistan
2 Bahamas
3 Barbados
4 Botswana
5 Kambodża
6 Ghana
7 Iran
8 Irak
9 Jamajka
10 Democratic People's Republic

of Korea
11 Mauritius
12 Morocco
13 Mjanma/Birma
14 Nikaragua
15 Pakistan
16 Panama
d) Customer behavior - behavioral factor
In the case of customer risk assessment, the obliged
institution's co-workers take into account the customer's
behavior and assess it in terms of abnormal behavior. In such a
situation, the obliged institution's employee should take this
factor into account in the risk assessment. A situation that
should draw the associate's special attention is the presence of
an additional person at the transaction, especially when
instructing the client on what to do.
e) Client transactions (size and geography)
Assess the client for agreements and transactions that are
inconsistent with the client's business profile - if the client's
behavior cannot be reasonably explained this should be included
in the risk assessment.
f) Customer presence
The absence of the customer at the conclusion of the contract
and also during the relationship is considered a higher risk
factor.
17 Russia
18 Syria
19 Trinidad i Tobago
20 Uganda
21 Vanuatu
22 Jemen
23 Zimbabwe
24 Belarus
25 Sudan
26 Cuba
27 Haiti
28 Gwatemala
29 Argentina
30 Belize
31 Crimea, Donetsk and Luhansk
(Ukrainian regions)
g) New products, channels, technologies
If a client intends to provide new services, products, distribution
channels or technologies this may lead to an increased
AML/CFT risk. This risk will not always relate directly to the
client but needs to be assessed in terms of the security of the
obliged institution.
h) Client status
If the customer is a politically exposed person, a family member
of such a person or a person known to be a close associate, or
the person is on a warning or sanctions list then this is a
significant factor for a higher risk assessment.
Lower risk may be indicated by the fact that the client is:
a) Public sector entity,
b) State-owned enterprise or a company with a majority stake held
by the State Treasury, local government units or their
associations,
c) A company whose securities are admitted to trading on a
regulated market subject to beneficial ownership disclosure
requirements, or a company with a majority stake in such a
company,
d) A resident of a member state of the European Union, a member
state of EFTA - a party to the EEA Agreement,
e) 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,
f) Resident of a third country where according to reliable sources
AML/CFT regulations are in force.
A lower risk may also be evidenced by having a business
relationship or occasional transaction with:
a) A Member State of the European Union, an EFTA Member State
party to the EEA Agreement,
b) A third country described by reliable sources as a country with
a low level of corruption or other criminal activity,
c) A third country, where according to reliable sources AML/CFT
regulations are in force.
Increased risk may be indicated in particular by:
a) the establishment of business relationships in unusual
circumstances.
b) that the client is:
- a legal person or an unincorporated organizational unit whose
business is used to hold personal assets,
- a company in which bearer shares have been issued whose
securities are not admitted to organized trading, or a company
in which the rights from shares are exercised by entities other
than shareholders or members,
c) the subject of the client's business activity involving a
significant number or high value of cash transactions,
d) unusual or excessively complex ownership structure of the
client, considering the type and scope of its business activity,
e) the customer's use of private banking services or products,
f) use by the customer of services or products that promote
anonymity or make it difficult to identify the customer,
g) establishing or maintaining a business relationship or
conducting an occasional transaction without the physical
presence of the customer - where the associated higher risk of
money laundering or terrorist financing has not been mitigated
otherwise, including by the use of electronic identification
means,
h) ordering by unknown or unrelated third parties of transactions
benefiting the customer.
i) to extend the business relationship or transactions to new
products or services or to offer products or services through
new distribution channels,
j) linking the business relationship or occasional transaction to:
- a high-risk third country,
- a business relationship or occasional transaction with a high-
risk third country, a country that is identified by reliable sources
as a country with a high level of corruption or other criminal
activity, a country that finances or supports the commission of
terrorist acts, or with which the activity of a terrorist
organization is associated
- a state with respect to which the United Nations or the
European Union has
decided to impose sanctions or specific restrictive measures.
Absolutely high AML/CFT risk occurs in particular when:
a) The Client is from or based in a high-risk third country,
b) The Client has a PEP status,
c) Relationships are concluded under correspondent banking,
d) The transaction has the status of an unusual transaction.

4. Principles of applying financial security measures
1) Financial security measures shall be applied when:
a) The establishment of a business relationship (showing the
characteristic of permanence).
b) conducting an occasional transaction:
- of the equivalent of 15,000 euros or more, regardless of whether
the transaction is conducted as a single operation or several
operations that appear to be linked, or
- which represents a transfer of funds for an amount exceeding
the equivalent of 1,000 euros.
- with the use of virtual currency of the equivalent of 1,000 euros
or more - in the case of mandatory institutions referred to in
Article 2, paragraph 1, point 12;
c) conducting an occasional cash transaction of the equivalent of EUR
10,000 or more, regardless of whether the transaction is conducted
as a single operation or as several operations that appear to be
linked - in the case of obliged institutions referred to in Article 2,
paragraph 1, point 23.
d) placing bets and collecting winnings of the equivalent of EUR 2,000
or more, regardless of whether the transaction is conducted as a
single operation or as several operations that appear to be linked
- in the case of obliged institutions referred to in Article 2,
paragraph 1, point 20.
e) suspicion of money laundering or terrorist financing.
f) doubts as to the accuracy or completeness of customer
identification data obtained to date.
Simplified financial security measures may be applied where a risk
assessment confirms a lower risk of money laundering or terrorist
financing.
Enhanced security measures shall apply where there is a higher risk of
money laundering or terrorist financing, and in particular, in the case of
customers from or established in a high-risk third country. Enhanced
security measures may consist, in particular, in verifying the customer
with more than one of the required documents.
2) The manner of applying financial security measures
Financial security measures include:
a) Identification of the customer and verification of his identity,
including in particular whether he is a politically exposed person.
b) Identification of the beneficial owner and verification of the
beneficial owner.
c) Assessment of business relationships and their ongoing monitoring.
3) Customer identification consists of obtaining, in the case of:
a) an individual:
i. first and last name,
ii. citizenship,
iii. ID number or date of birth - in case the ID number has not been
assigned and country of birth,
series and number of the document confirming identity of the
person,
iv. the address of residence - if the obliged institution has this
information,
v. name (company), tax identification number and address of the
main place of business activity - in case of a natural person
conducting business activity.
b) a legal person or an organizational unit without legal personality:
i. name (business name),
ii. organizational form,
iii. registered office or business address,
iv. Tax identification number, and if there is no such number - the
country of registration, the name of the relevant register and
the number and date of registration,
v. identification data referred to in item 1 letters a and c of the
person representing that legal person or organizational unit
without legal personality.

Determination of whether the client is a politically exposed person is
made by verification of the obligated institution or by the client's
declaration before using the service and ongoing checking of the
information obtained to identify and verify the person. The client submits
a statement that he or she is not a person holding such a position with
the clause "I am aware of the criminal liability for making a false
statement".
Identification of the person authorized to act on behalf of the customer is
based on the determination of the data in point 3 above letter a,
designation ii-iv.
4) Identification of the beneficial owner:
Includes establishing his/her name and, where possible, the data
indicated in point 3 above designation ii-vi.
5) Verification of individuals:
Verification shall consist of confirming the established identification
of the persons in point 3 above, based on:
a) identity document.
b) driver's license.
c) passport.
d) bank account statement.
e) bank transfer confirmation.
f) or on the basis of any other document, data or information coming
from a reliable and independent source.
6) Verification of corporates:
Verification shall consist of confirming the established identification
of the legal entity in point 3 above, based on:
a) legal representative information
b) UBO’s passports/ID’s
c) certificate of incorporation
d) articles of association with disclosure of any affiliates (if any)
e) confirmation of the address
f) UBO declaration
g) confirmation of source of funds
h) bank account statement
i) bank transfer confirmation
The documents listed above must be submitted all together as a
package.
j) The assessment of economic relations and their ongoing
monitoring consists in taking actions leading to the assessment
whether:
a) The making of transactions by a person/entity does not show the
characteristics of permanence (especially repetition and
regularity).
b) Transactions made by the customer do not violate regulations
related to the Money Laundering and Terrorist Financing Act.
c) The funds used for the transaction do not come from undisclosed
or illegal sources.
d) Identification data and verification documents held are updated on
an ongoing basis.
e) There are no other irregularities resulting in possible violations of
applicable laws.
k) When one of the financial security measures cannot be applied,
what does the obliged institution do?
a) Does not establish business relations.
b) Does not conduct an occasional transaction.
c) does not conduct a transaction through a bank account.
d) terminates the business relationship.
l) Business relations with a politically exposed person
In accordance with the applicable regulations, if a risk analysis is
carried out showing that a transaction is to be carried out with a
politically exposed person (as customer or beneficial owner), the
obliged institution MAY carry out such a transaction. However, in such
a case, the person conducting the transaction shall obtain senior
management approval for such action, and the obligated institution
shall:
1) apply appropriate measures to determine the source of the
customer's property and the source of the property values at the
customer's disposal under the business relationship or transaction.
2) intensify the application of financial security measures.
For these purposes, the obliged institution may use Attachment No. 1.
m) The effect of the existence of the Client on the sanction lists
The obliged institution also applies financial security measures in the
following areas
Establishing business relations and conducting transactions with
Customers on sanction lists, including in particular:
a) Those designated by the Financial Analytical Unit (FAU) of Czech
Republic (Supervisory Authority in the Czech Republic)
(https://www.financnianalytickyurad.cz/en),
b) The list included in OFAC
(https://sanctionssearch.ofac.treas.gov/),
c) Other lists selected on an ongoing basis, according to the existing
risks and information acquired.
In the case of a Client's appearance on one of such lists, the Obligated
Institution shall not establish a relationship or conduct transactions
with it. If the Obligated Institution is in the process of a transaction,
then it shall apply the detention of funds and transfer to a depository
designated by the competent Prosecutor. In case the Obligated
Institution has a relationship then it shall terminate such economic
relationship.
The fact that controls are applied is recorded on an ongoing basis in
the Notes in Customers reports.
5. Rules for retention of records and information.
An obliged institution and its employees are obliged to document the
applied financial security measures, e.g., by making copies of documents,
screenshots with the date, or in any other way. The documentation is
kept for 5 years, counting from the date of termination of business
relations with the customer or from the date of execution of an occasional
transaction. Documents are stored in a manner ensuring their safety and
in accordance with regulations on personal data protection. These issues
are regulated by separate internal procedures.
6. The principles of performing duties involving the transmission of
information on transactions and notifications to the FAU.
The purpose of the procedure is to determine events and situations that
require an obliged institution to report to the FAU. The reporting
obligation of an obliged institution consists in:
a) Reporting of suprathreshold transactions,
b) Reporting to the FAU on suspicious circumstances.
The organization cooperates with the authorities also in the situation of
request for information.
1) The Management Board:
a) receives reports and assesses the appropriateness of further
reporting to the supervisory authority,
b) is responsible for training employees on how to inform and report
necessary events,
c) cooperate with the authorities and provide them with the necessary
documents and information.
2) Associates:
a) Report the events described in the procedure,
b) in case of becoming aware of a person who made a report - ensure
that his/her data is not disclosed to other employees and that the
reporting person does not bear negative consequences related to
the report,
c) where they become aware of a person who has been reported as
potentially or actually responsible for a breach of AML/CFT rules,
ensure that this information is kept confidential.
3) Situations in which an obliged institution submits information to the
FAU:
a) accepted deposit or executed withdrawal of funds of the equivalent
of more than EUR 10 000,
b) executed transfer of funds of an amount exceeding the equivalent
of EUR 15,000, with exceptions specified by law.
The organization is obliged to immediately notify the FAU in case of
reasonable suspicion that a given transaction or assets may be related
to money laundering or financing of terrorism. An employee,
associate, trainee, and any other person who will have a reasonable
suspicion of the above shall communicate the information to the Board
of Directors by email or verbally. The deadline for providing the
information shall be immediate. The Board of Directors shall decide
without undue delay on the further fate of the notification. Since the
acknowledgement of the notification, the obliged institution shall not
conduct transactions.
4) Notification of a suspected crime
An obliged institution, excluding domestic banks, branches of foreign
banks, branches of credit institutions and cooperative savings and
credit unions, shall immediately notify the competent public
prosecutor if it has a reasonable suspicion that the property values
transacted or accumulated in the account are derived from or related
to an offence other than the offence of money laundering or terrorist
financing or a fiscal offence.
7. Principles of dissemination of knowledge of the anti-money laundering
and terrorist financing regulations among employees of the obliged
institution.
Senior management provides access to knowledge of the AML and
terrorist financing regulations among its co-workers, including
employees. This involves, in particular:
a) Providing updated guidance and other courses of action,
b) Providing written, electronic, and verbal information and
explanations,
c) Informing about changes in regulations,
d) Providing at least initial access to training (possibly in the form of
an on-line video) on the subject of anti-money laundering and
terrorist financing.

8. Rules for employees to report actual or potential violations of anti-money
laundering and terrorist financing regulations
A procedure has been implemented in the obliged institution, which
allows employees and other persons performing activities (hereinafter
referred to as "other persons") for the benefit of the obliged institution
to report actual or potential violations of regulations in the field of
anti-money laundering and terrorist financing. The procedure is that
these persons have been provided with an e-mail address to which
they can make reports. Reports can therefore also be made
anonymously. In connection with the above:
a) The persons acting as members of the Board of Directors are
the persons responsible for receiving reports.
b) Reports shall be received by reading the e-mail and taking
appropriate action thereon.
c) The data of the employee or other person are subject to special
protection, so that the contents of the notification are not made
available to anyone outside the management board. The obliged
institution is obliged to ensure such working conditions that the
person making the report does not experience any negative
actions, including discriminatory, repressive ones, in connection
with the report.
d) If the identity of the persons making the report or to whom the
report relates is disclosed and the identity of those persons can
be ascertained, senior management shall determine the circle of
persons who may have had access to it and instruct them of
their duty of confidentiality and the consequences of not
complying.
e) Upon receipt of a report, senior management shall review the
report and, if the report is found to be legitimate, shall take
appropriate action, including but not limited to:
- suspend the transaction,
- notification of suspicion of committing a crime,
- notification of the FAU.

9. Principles of internal control or supervision of the compliance of the
obliged institution with the anti-money laundering and counter-terrorist
financing regulations and the rules of conduct set forth in the internal
procedure.
Senior management:
a) Analyze changes in AML and terrorist financing regulations on
an ongoing basis to ensure compliance with the procedure,
b) In case of changes or perceived inconsistencies or lack of
precision, they take actions resulting in adjustments to the
procedure,
c) Supervise on an ongoing basis how the procedure is being used
in practical terms to ensure that it is as effective as possible.
For this purpose, a report on internal control and supervision is
prepared in accordance with the requirements and development of
the obliged institution.
10.Rules for noting discrepancies between the information collected in the
Central Register of Beneficial Beneficiaries and the information on the
customer's beneficial owners determined in connection with the
application of the Act.
In the case of risk analysis, as well as customer identification and
verification, in case of recording discrepancies between the
information collected in the Central Register of Beneficial Owners
and information on the customer's beneficial owners established in
connection with the application of the Act, an annotation to this
effect is made in the Customer File.

11.Rules for documenting impediments identified in connection with
verification of the identity of the beneficial owner and actions taken in
connection with identification as a beneficial owner of an individual
holding a senior management position.
In the case of difficulties identified in connection with verification
of the identity of the beneficial owner and actions taken in
connection with identification of a natural person holding a senior
managerial position as the beneficial owner, a note is made in the
Client's File.

12.Rules for AML officer advanced training
Once in 6 months (Training Period) the responsible for compliance AML
officer have to go through the additional trainings in order to obtain
necessary qualification and development of skills. AML officer trainings
have to be selected by the CurrencyCorner s.r.o. or by the responsible
AML officer one month prior to the Training Period. Selected AML officer
trainings have to be certified either by government or by special authority
responsible for certification of such trainings. After Training Period, the
responsible AML officer have to provide CurrencyCorner s.r.o. with the
confirmation of completion of the compliance trainings.

28 of February, 2024