AML POLICY

GENERAL PROVISIONS

1. The purpose of these Internal Rules is to establish the measures adopted by Cryptos Fund Trading™ to prevent money laundering and to detect and prevent the activities of natural persons and legal entities, groups, and organizations aiming to finance terrorism (the “Purposes”), and the controls related to their implementation.

2. The Internal Rules are the basis on which Cryptos Fund Trading™ provides and regulates its activity, in strict observance of the legislation in force.

3. The Internal Rules establish clear principles for effectively identifying suspicious operations, transactions and clients.

4. The Internal Rules provide for, and regulate, the mandatory rules to be obeyed by Cryptos Fund Trading™, its employees, associates, affiliates, subcontractors, subsidiaries and agents.

5. Money laundering is a three-phase process:

• Placement – the realization of an initial deposit into the financial system, or of an initial transformation of the funds acquired through, or in relation to, a crime, in order to obstruct its identification;
• Layering – performance of multiple, usually cross-border financial and other business operations and transactions with the property, which significantly impedes the establishment of its criminal nature;
• Integration – finalization of the process, as the property is “integrated” or invested in the legal economy.

MEASURES AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM (“AML POLICY”)

Cryptos Fund Trading™ has a strict AML POLICY in place to prevent its clients from using it to launder money. The AML POLICY includes the following measures:

1. Identification of clients and verification of their identity:

• The identity verification procedure of Cryptos Fund Trading™ requires all potential clients to provide Cryptos Fund Trading™ with reliable, independent source documents, data, or information (e.g. national ID, international bank statement or utility bill).
• Cryptos Fund Trading™ reserves the right to collect identification information from its potential clients for such Purposes.
• Cryptos Fund Trading™ will take steps to confirm the authenticity of documents and information provided by the clients. Cryptos Fund Trading™ reserves the right to investigate clients who have been determined to be risky or suspicious.
• Cryptos Fund Trading™ reserves the right to verify the identity of clients on an on-going basis, especially when their identification information has been changed or their activity seems suspicious (unusual for the particular client). In addition, Cryptos Fund Trading™ reserves the right to request up-to-date documents from its clients.
• The identification information of clients will be collected, stored, shared and protected strictly in accordance with the Personal Data Protection and Privacy Policy of Cryptos Fund Trading™ (published at cryptosfundtrading.com).
• Once the client’s identity has been verified, Cryptos Fund Trading™ shall not be held liable in a situation where the services provided by it are used to conduct illegal activity.

2. Identification of the client’s beneficial owner (beneficiary) if the client is a legal entity, and taking appropriate actions to verify his or her identity in a way that gives sufficient reason to believe that he or she is indeed the beneficial owner.

3. Collection of information from clients regarding the purpose and the nature of the relationship established, or to be established, with them.

4. On-going monitoring of the established business or professional relations and the transactions and operations executed under these relationships, to check to what extent they correspond to the available information about the client and their commercial activity and risk profile, including by investigating the origin of the funds, in the cases stipulated by relevant and pertinent laws.

5. Monitoring of all transactions relative to the AML Policy. Cryptos Fund Trading™ thereby reserves the right to:

• Ask the client to provide any additional information and documents in case of suspicious transactions;
• Suspend or terminate its business relationship with its client when Cryptos Fund Trading™ has reasonable grounds to suspect that said client is engaged in illegal activity.
• Disclose information regarding suspicious operations, transactions, and clients to the competent state authority;

The above list is not exhaustive and Cryptos Fund Trading™ will monitor clients and their transactions/operations carried out by them on a day-to-day basis in order to define whether such clients and the transactions/operations carried out by them are to be treated as suspicious.

These Internal Rules have been implemented to protect both Cryptos Fund Trading™ and its clients.