KYC/AML Policy

Anti–Money Laundering and Counter–Terrorism Financing Policy

Introduction and purpose

"2015 invest Group" LLC (hereinafter referred to as the “Company”) management is committed to combating financial crime, terrorist financing and money laundering (hereinafter referred to as AML/CTF).

The company's director(s) actively implements an effective system for assessing and managing AML/CTF risks, taking into account the nature and scope of the activities, and appoints specialized and trained personnel for this purpose.

For the above purpose, this policy has been developed, which defines the main guiding principles for combating money laundering and terrorist financing.

The provisions set out in this document are based on the Law on the Prevention of Money Laundering and the Financing of Terrorism (hereinafter referred to as the “Law”), the provisions of the Financial Monitoring Service (hereinafter referred to as the “FMS”), the normative acts and guidance documents of the National Bank of Country, the recommendations of the Financial Action Task Force (FATF) and other relevant international organizations, which currently set the standards for combating money laundering and the financing of terrorism.

Scope of distribution and responsible persons

The requirements set forth in this Policy apply to all employees who have direct contact with clients, as well as to other personnel serving client operations in the relevant structural units, as well as to all service providers acting on behalf of the Company.

in the company is the Director. In addition, the organization's ML/TF risk analysis function is delegated to the structural unit implementing monitoring — the AML Compliance Direction (AMLO).

Definition of terms

Legalization of illegal income (money laundering)

Legalization of illegal income, that is, giving illegal and/or undocumented property a legal form (use of property, acquisition, possession, conversion, transfer or other action) for the purpose of covering up its illegal and/or undocumented origin and/or assisting another person in evading liability, as well as concealing or disguising its true nature, source of origin, location, disposition, movement, ownership and/or other rights related to it;

Financing of terrorism

The collection or provision of funds or other property with the prior knowledge that they will be or may be used in whole or in part by a terrorist or terrorist organization and/or to carry out terrorist activities and/or with the prior knowledge of providing services to a terrorist or terrorist organization, providing a hiding place or shelter to a terrorist, and/or providing resources or other material support to a terrorist or terrorist organization;

Suspicious transaction

A transaction for which there is a reasonable suspicion that it was prepared, concluded or executed on the basis of illegally obtained property or proceeds from such property and/or for the purpose of money laundering or is related to the financing of terrorism;

Client

A person who establishes a business relationship with a company or enters into a one-time transaction with the aim of using its services;

Business relationship

An ongoing commercial or professional relationship between the Company and the Client, which involves the provision of services by the Company to the Client as defined by the country legislation;

One-time transaction

A transaction (other than a transaction prepared, concluded or executed within the framework of a business relationship) that provides for the provision of services by the Company to the Client as defined by the legislation of the country;

Identification

Obtaining information (document) that allows the accountable person to verify the accuracy of the identification data obtained about the person, and in the case of a beneficial owner, also to ensure that the identity of the beneficial owner is known to him/her.

Verification

List of sanctioned persons

List of individuals and legal entities subject to sanctions by UN Security Council resolutions, the US, UK, EU and Russia and Belarus; the sanctions provided for apply.

Politically active person

A natural person performing important public or political functions (except for middle and low-ranking officials), including: a) Head of State, Head of Government, Member of Government (Minister), Deputy Head, Head of a State Institution; b) Member of the Legislative Body (Parliament); c) Head of a political union, Member of a governing body; d) Member of the Supreme Court, Constitutional Court, other judicial body of the highest instance, whose decisions are subject to appeal in exceptional cases; e) Auditor General, Deputy Auditor, Member of the Court of Auditors; f) Member of the Board of the National (Central) Bank; g) Ambassador, Head of a Diplomatic Mission; h) Head of the Defense (Military) Forces; i) Head of an enterprise operating with state participation, Member of a governing body; j) Head of an international organization, Deputy Auditor, Member of a governing body.

Family members of a politically active person

Spouse/person with whom a politically active person permanently maintains a joint household, sister, brother, parent, child/grandchild, and spouse/person of a child/grandchild with whom he permanently maintains a joint household;

Person associated with a politically active person

A natural person who, together with a politically active person, is a beneficial owner of a legal entity, unregistered organizational entity, or trust or legal structure similar to a trust, or who has another close business, social, or political relationship with him/her. A natural person who is the de facto (informally) beneficial owner of a legal entity, unregistered organizational entity, or trust or legal structure similar to a trust created for the benefit of a politically active person.

Beneficial owner

A natural person who is the ultimate owner or ultimate controlling person of a person and/or on whose behalf a transaction is prepared, concluded or carried out. The beneficial owner of an entrepreneurial legal entity (as well as an organizational formation provided for by the legislation of the country that is not a legal entity) is a natural person who directly or indirectly owns, owns and/or controls 25 percent or more of its shares and/or voting shares or a natural person who otherwise exercises control over the management of the entrepreneurial legal entity.

Controlling person of a legal entity

A natural person who has the power to exercise significant influence over the management of a legal entity, directly or indirectly, directly or jointly with others, through the use of voting shares (shares, stakes) or otherwise;

Legal entity

Both resident and non-resident entrepreneurial legal entities, non-entrepreneurial (non-commercial) legal entities (NON-RECs), as well as organizational formations provided for by legislation that are not legal entities, as well as their branches and representative offices;

Non-profit (non-commercial) legal entity

Non-entrepreneurial (non-commercial) legal entity of private law (NPL) defined by legislation, as well as organizational formations not having the status of a legal entity: unregistered union, political association of citizens (party), electoral bloc, voter initiative group, fund, union, federation, church;

Trust

A trust function, in which the property belonging to the owner is transferred to the trustee (or guardian) for management on the basis of a special agreement (trust declaration), who in turn is obliged to carry out those operations that result in the maximum profit desired by the beneficiary or to be guided by other instructions of the owner. The income received as a result of management is shared by the beneficiaries of the income, the owner may at the same time be a beneficiary of the income. Also, the legal relationship defined in Article 2 of the Hague Convention of 1 July 1985 on the Law Applicable to Trusts and their Recognition or a structurally/functionally similar relationship;

High-risk jurisdiction

High-risk jurisdictions as defined by the order of the President of the National Bank of the country;

Offshore zone

Offshore jurisdiction approved by order of the President of the National Bank of the country.

Corporate/Ownership Structure

The entire/continuous chain of the founders of a legal entity up to the ultimate beneficial owner;

RBA

Risk-based approach;

KYC (Know Your Customer)

"Know Your Customer (KYC)"

KYCUB (Know Your Customer's Ultimate Beneficiary

"Know Your Customer's Beneficial Ownership (KYCUB)"

EDD (Enhanced Due Diligence)

Enhanced remediation measures as defined by the company's KYC policy;

SPMS

Financial Monitoring Service of the country;

AMLO

AML Officer responsible for the AML/Compliance direction of the company .

Note: Other terms used in this policy have the meanings defined by law and other normative acts of the country.

Scope of the reports and responsible persons

The requirements set forth in this Policy apply to all employees of AIKSAI LLC who have direct contact with clients, as well as to other personnel serving client operations in the relevant structural units.

in the company is the Director. In addition, the organization's ML/TF risk analysis function is delegated to the structural unit implementing monitoring — the AML Compliance Direction (AMLO).

The above-mentioned persons are obliged to:

Familiarize themselves with and, within their competence, strictly comply with AML/CTF related procedures;
In the event of any information or suspicion of financial crime, immediately report it to AMLO;
Pay due attention to possible suspicious circumstances when performing or attempting to perform any operation and act in accordance with existing rules;
Participate in training programs related to AML/CTF issues organized by the company;
The company will employ responsible, ethical, and appropriately qualified personnel.
All employees will undergo training on identifying money laundering operations once a year. New employees who must have direct contact with clients will undergo training within the first four weeks of employment.

The Anti-Money Laundering Officer (AMLO) is responsible for:

Developing programs for preventing money laundering and terrorism, organizing and executing their implementation;
Development of regulatory documents for the AML/CTF compliance control system — policies, rules, procedures and their regular updating;
Monitoring ML/TF risks across the company;
Monitor the effectiveness of ML/TF risk management mechanisms and ensure the implementation of new mechanisms in accordance with regulatory requirements and international best practices;
The AMLO is accountable to the company's directors and is responsible for the effectiveness of the company's ML/TF compliance control system.
AMLO is granted the authority to have direct access to information/documents necessary for the performance of his functions and to independently decide on the submission of relevant reports.
The AMLO must understand the responsibility placed upon him to ensure AML/CTF compliance at all times.
AMLO shall immediately inform the company's director of any identified deficiencies or deficiencies in ML/TF control mechanisms.

The responsibilities of company directors include:

Approval of the organizational AML/CTF risk assessment methodology;
Approval of the AML/CTF risk appetite document;
Making decisions on establishing, terminating or continuing business relationships with clients classified as high risk;
Monitoring ML/TF risks across the company;
Providing the AML Division with sufficient resources necessary to properly perform its duties, including additional support staff if necessary;
Participate in the process of developing a company's compliance culture and foster a culture of compliance;
Approval of AML/CTF policies/procedures.
Considering the consequences of ML/TF risks across the organizational group;
Monitoring the implementation of recommendations determined by the person responsible for monitoring and supervision;
Developing an action plan to correct any deficiencies identified during the review of the results of the organization-wide ML/TF risk analysis.
Monitoring the implementation of recommendations determined by independent audit and supervision for AML Compliance;

The powers of the independent audit are:

Assessing the organization's ML/TF risk assessment methodology and effectiveness (at least once every 2 years) and presenting the results and recommendations to the company's director;
Auditing the company's ML/TF risk processes and determining appropriate recommendations based on identified deficiencies and presenting the results and recommendations to the Director;
Assessing the effectiveness and efficiency of ML/TF control measures ;
And more.

Assessing and managing money laundering and terrorist financing risks

The company has implemented procedures for identifying and assessing AML/CTF risks and takes proportionate measures to manage these risks using a risk-based approach.

The company has developed a unified concept of risk-based approaches to client assessment, which includes risk identification, analysis, implementation and implementation of risk-appropriate preventive measures, as well as the creation of an effective risk management strategy.

The Company ensures that risk-based approaches are taken into account, both with respect to persons wishing to establish a business relationship with the Company, as well as with persons in long-term business relationships with it, and with persons carrying out a one-time operation/transaction.

The company ensures the definition of appropriate criteria based on the level of risk, with which the company will effectively assess future and expected risks from persons interested in receiving its services.

The Company ensures that individuals interested in receiving its services and/or existing clients are assigned an adequate risk level through a client risk assessment policy.

AML/CTF risks are determined based on the client and beneficial owner, the nature of their business and jurisdiction of location, and other risk factors.

Appropriate risk levels are determined for each group of clients, areas of activity, geographical area of jurisdictions, and service/product.

Depending on the risk levels, the client is assigned a high, medium, or low risk category.

The measures taken to manage risks related to clients depend on the level of risk assigned, namely, standard preventive measures are applied to medium-risk clients, enhanced preventive measures to high-risk clients, and simplified preventive measures to low-risk clients.

The assessment of ML/TF risks related to the client and the determination of the client's risk level are carried out prior to establishing a business relationship with the client, as well as at periodic intervals established by this policy — during the course of the business relationship and when material circumstances related to the client change

Preventive measures

The basis of the AML/CFT compliance control system is the “know your customer” principle.

“Know Your Customer” approaches and standards are governed by this Policy and the “Know Your Customer (KYC) and Preventive Measures Policy”.

For the purposes of this policy, the Company implements preventive measures required by law, including the following:

Identification of the client and its verification based on a reliable and independent source;
Identification of the beneficial owner/person responsible for the authority of the I/P and taking reasonable steps to verify and rely on a reliable source;
Determining the purpose and intended nature of the business relationship;
Assigning the appropriate risk level to the client.
Monitoring business relationships;

The implementation of preventive measures is mandatory in the following cases:

Establishing a business relationship;
A business relationship is established if the amount of a single transaction exceeds 1,000 USD or 1,000 EUR ;
Doubts about the accuracy of identification data obtained about the client or its compliance with legal requirements;

Enhanced preventive measures must be implemented for clients classified as high risk, as well as in high-risk cases defined by this policy:

Obtaining additional information/documentation about the property and activities of the client and/or beneficial owner (in particular, current activities, the scope of activity and location of the employing company, information about the convertible virtual asset, source of income and property, activity history, reputation, etc.).
Determining the intended nature of the business relationship, including the purposes and basis of the transactions prepared, concluded or executed, and additional information (including a description of the client's business operations, obtaining information about contractors, suppliers, customers, the location of the client's residence, workplace or business, etc.);
Obtaining permission from the director to establish or continue a business relationship;
Taking reasonable steps to determine the origin of client property, convertible virtual assets, and cash.
In certain cases, in order to mitigate risks, the client may be restricted from accessing a particular product, be subject to a limit on the volume/number of transactions, etc.

Enhanced monitoring of business relationships, which includes at least the following additional measures:

Review/update existing information/documentation about the client at least once a year to verify whether the client's risk level has changed and whether the risk is still manageable;
Studying the basis (purpose and destination) of the client's transactions, the persons and funds involved in them, and the source of origin of the convertible virtual asset;
Continuous monitoring of whether the information previously declared by the client corresponds to his actual actions during the business relationship in order to identify unusual/suspicious or unexpected transactions or sets of transactions.

The company will apply enhanced preventive measures if:

The client is a legal entity registered in a high-risk jurisdiction/offshore zone or a branch of such a legal entity registered in the country;
The client is an individual with a place of registration and/or actual residence in a high-risk jurisdiction/offshore zone.
The client's primary source of income is a high-risk jurisdiction/offshore zone.
The Client's place of birth is a high-risk jurisdiction (see Client Risk Assessment Policy).

When implementing preventive measures before carrying out a one-time transaction and entering into a business relationship, it should be determined based on verification of the relevant lists whether the client or beneficial owner is a politically active person, a family member of a politically active person, and/or a person associated with a politically active person.
If the client or beneficial owner, person authorized to manage, founder (I/P, F/P) is a politically active person, a family member of a politically active person and/or a person associated with a politically active person, when establishing a business relationship, the client must be assigned an unconditionally high risk level and the following enhanced preventive measures must be implemented in relation to him/her:
Obtaining permission from management to establish or continue a business relationship;
Taking reasonable measures to determine the origin of assets, convertible virtual assets and cash of a politically active person;
Implement enhanced monitoring of business relationships.
The Company considers the continuing risks associated with politically active persons after the client or beneficial owner ceases to perform significant public or political functions.

In accordance with the identified risks, simplified preventive measures are implemented for clients classified as low risk, which include:

Updating the identification data of the client and/or beneficial owner every five years;
Determining the purpose and intended nature of the business relationship, depending on the type of business relationship or transaction;

It is not permissible to establish a business relationship or perform a one-time transaction if one of the following cases exists:

There is a reasonable suspicion that the client, the client's beneficial owner, a person included in the entity's constituent structure, or another person participating in the transaction is designated by UN Security Council resolutions, the US, the UK, and Russia and Belarus — included in the list of sanctioned persons;
The Company is not confident that it will be able to effectively manage the risks associated with the business relationship and/or one-time transaction;
A terrorist and/or a person who is reported/suspected of facilitating the financing of terrorism or a terrorist organization;
and other cases provided for by the company's policies and procedures;
A business relationship established with a client in a business relationship must be terminated if any of the above circumstances exist.

Client identification and verification

Before establishing a business relationship or concluding a one-time transaction, the client must be identified and the identification data must be verified based on a reliable and independent source.

Basics of Identification and Verification — the company is obliged to carry out client identification and verification:

When establishing business relationships;
When making a one-time transaction.

In order to identify an individual, obtain the following identification data:

First and last name;
Date of birth;
Personal number (if any);
Number of the identity and/or citizenship document, date of issue, issuing country, issuing authority and validity period;
Gender;
Citizenship;
Place of birth — country (as well as city — if such data exists);
Registration address;
Actual place of residence.

A client legally residing in Abkhazia / Tskhinvali region — identification data:

First and last name; Date of birth; Personal number;
Number of the neutral certificate or neutral travel document, date of issue, issuing country, issuing authority and validity period (if such a document exists);
Gender; Place of birth — country (as well as city — if such data exists); Address.

If the client is a natural person or an individual entrepreneur and a business relationship is established for entrepreneurial purposes, obtain:

First and last name; Date of birth; Personal number (if any);
Number of the identity and/or citizenship document, date of issue, issuing country, issuing authority and validity period; Gender; Citizenship;
Place of birth — country (as well as city — if such data exists); Taxpayer identification number; Legal address; Date of registration.

Minimum dataset:

At least name, surname and personal identification number (if absent — date of birth) or the identification data above, if the amount of a single transaction or the total amount of related transactions does not exceed 1000 USD.

Verification documents for an individual:

Passport; certificate of a compatriot living abroad;
Legally residing in Abkhazia/Tskhinvali — neutral identity card or neutral travel document (if only personal number is assigned — verify via State Services Development Agency database);
Foreign citizen — residence certificate/temporary ID issued by the State Services Development Agency, passport, other document permitted for border crossing, or certificate of a compatriot living abroad;
Stateless person — residence certificate/temporary identification card or travel passport;
Individual entrepreneur — a document per above and an extract from the Register of Entrepreneurs and Non-Entrepreneurial Legal Entities;
Person under 14 — one of the listed documents or a birth certificate.

Note:

Verification of an individual is not mandatory when exchanging a virtual asset, if the transaction value does not exceed 800 USD.

For a legal entity, obtain:

Name; Date of registration; Legal address; Identification number (if any); Registration number (if any); Legal form; Address of actual residence.

Additionally obtain info about person(s) with managerial and representative authority:

Natural person — at least name, surname and personal identification number (or DoB / document number) or the identification data specified above;
Legal entity — name and identification or registration number (if absent — one of the identification data listed above).

If the client is a branch:

Obtain the parent enterprise name and details of manager/representatives. For an administrative body, international organization/financial institution or diplomatic mission — obtain the client's name, legal address and manager identification as above.

Verification of a legal entity is based on:

For entities registered in the country — an extract from the National Agency of Public Registry;
For entities registered in other jurisdictions — an extract from the relevant register and/or other official registration document.

Document freshness / alternative sources:

The verification document must contain up-to-date identification data and be issued no later than 12 months prior, unless verified through direct access to the relevant register. If insufficient, use another reliable and independent source.
If the client is a branch — verify the parent and its managers/representatives as well.
Verify administrative bodies, international organizations/financial institutions, and diplomatic missions via public or other reliable sources.

Know your customer standard

The Company considers the best way to manage AML/CTF risks to be raising awareness about the client and their activities and using this information effectively.

The Company is guided by the “know your customer” principle and implements risk-based preventive measures towards its clients.

The client's risk profile is determined based on information/documentation obtained as a result of preventive measures; according to the risk profile, the scope of additional information, content/format of supporting documentation, and the type (intensity) of ongoing monitoring — simplified, standard, and enhanced — are determined.

The decision to establish, continue or terminate a relationship depends on the analysis of documentation obtained during CDD. KYC is ongoing by nature and uses tools such as initial identification and file creation, analysis and independent verification, and periodic analysis based on risk level (high — 1 year, medium — 3 years, low — 5 years).

Enhanced preventive measures

The Company applies enhanced preventive measures to high-risk clients, including politically active persons, family members and close associates, when ML/TF risks are high. The client's risk level is determined according to the Company's internal document.

In addition to standard measures, implement at least:

Obtain and record additional information/documentation regarding the client's (beneficial owner) activities, income, convertible virtual asset, and source of origin of property;
Obtain information/documentation regarding the source of origin of cash/convertible virtual asset for a specific transaction;
Use appropriate measures to determine the origin of funds/assets (e.g., purchase agreement, inheritance certificate, salary statement, tax/customs declarations, commercial databases, media publications; audit reports; legal opinions, etc.).

Enhanced monitoring includes at least:

Annual review/update of client information to identify new circumstances and assess whether risks remain manageable;
Continuous monitoring to match declared vs. actual behavior and identify unusual/unexpected transactions;
Monitoring transactions to identify suspicious deals/transactions.

Director approval is mandatory to enter into or continue a business relationship with a high-risk client. The Company may restrict certain products/services (e.g., no remote registration, refuse PoA from abroad, set limits on virtual assets/transactions, etc.).
The Company also applies enhanced measures when the client is affiliated with a high-risk jurisdiction, e.g., transactions via a VASP located in a high-risk jurisdiction.

Ongoing monitoring

Throughout the relationship, the Company conducts ongoing risk-based monitoring, including selective verification of transaction content/geography vs. KYC questionnaire, annual verification of products, services and transaction volumes, requesting additional information as needed, and maintaining up-to-date records of identification data, purpose/nature of relationship, and reviewing risk levels.

Information related to the client (beneficial owners, authorized representatives, ownership structure, products) is checked regularly; records are updated; and the risk level is reassessed when new circumstances arise.

When beneficial owners/authorized managers change, services are provided only after (re)identification/verification of changed parties.

Risk reviews and updates occur at predetermined intervals and upon external triggers (negative media, state reports, sanctions, change of geography/activity/citizenship, etc.).

Compliance with international financial sanctions

Company operates in full compliance with financial sanctions imposed by the US, EU, UK, UN Security Council and Belarus and Russia in response to events in Ukraine. The Company does not serve or establish business relationships with such individuals and terminates business relationships with existing clients subject to sanctions.

The Company does not serve or establish a business relationship with a terrorist and/or a person known/suspected of facilitating the financing of terrorism or a terrorist organization; business relations with such persons are terminated.

Company performs screening of clients, managers/representatives, beneficial owners, founders, counterparties and all persons participating in the transaction:

Automated software ensures automatic verification at registration, one-time transaction and relationship establishment against: EU consolidated list; OFAC SDN; Denied Persons; FBI Most Wanted; Bank of England; HM Treasury; Non-Cooperative Countries & Territories; PEP; EU Terrorism; World Bank Ineligible Firms; DFAT; and Belarus/Russia sanctions (Ukraine).

Before establishing a relationship or executing a one-time transaction — screening against UN, EU, US, UK sanctioned lists and sanctions on citizens of Belarus and Russia (re: Ukraine events);
During the relationship — upon list updates; upon change to client/manager/BO data; upon ownership/control changes; upon suspicious activity; via daily automatic list updates; and by systematic verification of the entire client base once every 6 months.

Virtual asset address screening process

The Company screens virtual asset addresses/e-wallets:

Before the client initiates the exchange operation;
Before performing a one-time operation;
During scheduled verification of the client base (once every 6 months);

Dangerous circumstances

Child Exploitation
Dark Market
Dark Service (child abuse, terrorist financing, trafficking)
Enforcement action against the organization
Fraudulent Exchanges
Gambling (unlicensed online games)
Illegal Service
Mixer
Ransom
Sanctions (sanctioned persons/addresses)
Scam
Stolen Coins
Terrorism Financing

Questionable sources

ATM (self-service kiosk)
High-Risk Exchange (no KYC)
P2P Exchange Risk High (> $1,000/day without KYC/AML)
Moderate-Risk Exchange (> $2,000/day without KYC/AML)
Liquidity Pools (smart contracts with locked tokens)

Risk levels

Low — probability up to 20%
Medium — 20% to 50%
High — 50% to 80%
Unacceptable — over 80%
Regardless of risk level, exchange operations are prohibited if an address is associated with dangerous circumstances (e.g., sanctioned or terrorism-related addresses).

Information storage and confidentiality protection

Information (documents) obtained in accordance with the law and analysis results, as well as documentation and business correspondence related to the client's account, are stored for 5 years from the termination of the relationship or the conclusion of a one-time transaction (extendable by up to 5 years upon substantiated request from the SPMS or supervisory authority).

Transaction-related information/documents that allow complete retrieval are stored for 5 years from preparation, conclusion or execution (extendable by up to 5 years upon substantiated request). After the retention period, information is archived. Reports and other information/documents submitted to the FMS and written instructions/minutes given by the FMS are kept for at least 5 years.

Final provisions

This document has been approved by the director(s) of the company and may be amended only by decision of the director.

This policy and the procedures developed on its basis shall be reviewed at least once a year and submitted to the Director(s) for approval.

The internal policy procedures implemented in the company constitute a unified framework for the compliance control system, and the relevant processes are described/detailed in the form of separate documents/annexes, which are an integral part of this policy and are approved by order issued by the director(s).

KYC/AML POLICY

Anti–Money Laundering and Counter–Terrorism Financing Policy

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Introduction and purpose

Scope of distribution and responsible persons

Definition of terms